ML13099A161

FEMA Palisades Nuclear Plant, Final Exercise Report, Exercise Date - October 30, 2012

ML13099A161
Person / Time
Site:	Palisades
Issue date:	10/30/2012
From:	Federal Emergency Management Agency
To:	NRC/NSIR/DPR
References
Download: ML13099A161 (106)

Text

Palisades Nuclear Power Plant Exercise Date - October 30, 2012 Radiological Emergency Preparedness (REP) Program After Action Report/

Improvement Plan Published April 22, 2013 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Palisades Nuclear Power Plant After Action Report/Improvement Plan Published April 22, 2013 ContentsExecutive Summary6Section 1: Exercise Overview151.1Exercise Details 151.2Exercise Planning Team Leadership 151.3Participating Organizations 17Section 2: Exercise Design Summary212.1Exercise Purpose and Design 212.2Exercise Objectives, Capabilities and Activities 212.3Scenario Summary 21Section 3: Analysis of Capabilities233.1Exercise Evaluation and Results 233.2Summary Results of Exercise Evaluation 243.3Criteria Evaluation Summaries 343.3.1Indiana Jurisdictions 343.3.1.1State of Indiana - IDHS Watch Officer 343.3.1.2State of Indiana - State Emergency Operations Center 343.3.1.3State of Indiana - Joint Information Center - SEOC 343.3.1.4State of Indiana - Forward Operations Center -

Bremen 353.3.1.5State of Indiana - Indiana Field Sampling Team 1 -

Bremen 373.3.1.6State of Indiana - Indiana Field Sampling Team 2 -

Bremen 373.3.1.7State of Indiana - Indiana Field Sampling Team 3 -

Bremen 373.3.1.8State of Indiana - Indiana State Department of Health Radiochemistry Laboratory 38 1 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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3.3.2Michigan Jurisdictions 383.3.2.1State of Michigan - Initial Notification Point 383.3.2.2State of Michigan - State Emergency Operations Center 383.3.2.3State of Michigan - SEOC Technical Support Group 393.3.2.4State of Michigan - Field Team Center - MDOT Coloma 393.3.2.5State of Michigan - Field Team Center MDOT Coloma - Dosimetry Briefing - Emergency Worker /

Traffic and Access Control Point 393.3.2.6State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 1

MDOT Coloma 403.3.2.7State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 2 -

MDOT Coloma 403.3.2.8State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 3

MDOT Coloma 413.3.2.9State of Michigan - Michigan Department of Environmental Quality Radiological Protection

Laboratory 423.3.2.10State of Michigan - Michigan State Police - Traffic and Access Control Point 453.3.2.11State of Michigan - Allegan County Emergency Operations Center - State Liaison 453.3.2.12State of Michigan - Berrien County Emergency Operations Center - State Liaison 463.3.2.13State of Michigan - Van Buren County Emergency Operations Center - State Liaison 463.3.2.14State of Michigan - Joint Information Center - PNPP 463.3.2.15State of Michigan - Joint Information Center -

Rumor Control - PNPP 473.3.2.16State of Michigan - Berrien Springs High School -

Evacuee Monitoring and Decontamination - MDEQ

Representative 473.3.2.17State of Michigan - Covert Fire/EMS - Medical Service - Transportation - MDEQ Representative 473.3.2.18State of Michigan - Fennville High School - Evacuee Monitoring and Decontamination - MDEQ

Representative 48 2 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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3.3.2.19State of Michigan - South Haven Community Hospital - Medical Service - Facility - MDEQ

Representative 483.3.2.20State of Michigan - Watervliet HS - Emergency Worker Monitoring and Decontamination of

Equipment and Vehicles - MDEQ Representative 483.3.3Risk Jurisdictions 493.3.3.1Allegan County - Initial Notification Point 493.3.3.2Allegan County - Emergency Operations Center 493.3.3.3Allegan County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control Point 493.3.3.4Allegan County - Traffic and Access Control Point 503.3.3.5Allegan County - Joint Information Center Representative - PNPP 503.3.3.6Allegan County - Fennville High School - Evacuee Monitoring, Decontamination and Registration 503.3.3.7Allegan County - Fennville High School - Evacuee Vehicle Monitoring & Decontamination 513.3.3.8Allegan County - Fennville Jr High School -

Congregate Care Center 513.3.3.9Berrien County - Initial Notification Point 513.3.3.10Berrien County - Emergency Operations Center 523.3.3.11Berrien County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control Point 523.3.3.12Berrien County - Traffic and Access Control Point 523.3.3.13Berrien County - Joint Information Center County Representative - PNPP 533.3.3.14Berrien County - Berrien Springs High School -

Evacuee Monitoring, Decontamination &

Registration 533.3.3.15Berrien County - Berrien Springs High School -

Congregate Care Center 533.3.3.16Berrien County - Watervliet High School -

Emergency Worker Monitoring & Decontamination 543.3.3.17Berrien County - Watervliet High School -

Emergency Worker Vehicle & Equipment

Monitoring & Decontamination 543.3.3.18Van Buren County - Initial Notification Point 543.3.3.19Van Buren County - Emergency Operations Center 55 3 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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3.3.3.20Van Buren County - Dosimetry Briefing -

Emergency Worker / Traffic and Access Control

Point 553.3.3.21Van Buren County - Traffic and Access Control Point 553.3.3.22Van Buren County - Joint Information Center Representative - PNPP 563.3.3.23Van Buren County - Emergency Alert System Radio Station WSJM 563.3.3.24Van Buren County - Covert Fire/EMS - Medical Service - Transportation 563.3.3.25Van Buren County - Covert Public Schools -

Evacuation School 573.3.3.26Van Buren County - Mattawan High School -

Congregate Care Center 573.3.3.27Van Buren County - South Haven Community Hospital - Medical Service - Facility 57Section 4: Conclusion58Appendix A: Improvement Plan59 Appendix B: Exercise Timeline67 Appendix C: Exercise Evaluators and Team Leaders68 Appendix D: Acronyms and Abbreviations71 Appendix E: Exercise Plan74 4 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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EXECUTIVE

SUMMARY

On October 30 and 31, 2012, Radiological Emergency Preparedness (REP) Full Participation Plume Exposure Pathway and Ingestion Exposure Pathway Exercise evaluations were conducted

by the U.S. Department of Homeland Security (DHS) / Federal Emergency Management

Agency (FEMA) for the 10-mile and 50-mile Emergency Planning Zones (EPZs) around the

Palisades Nuclear Power Plant (PNPP). The purpose of these exercises was to assess the level of

State and local preparedness for responding to a radiological emergency. These exercises were

conducted in accordance with DHS/FEMA's policies and guidance concerning the exercise of

State and local Radiological Emergency Response Plans (RERPs) and procedures.

The most recent exercise at this site was conducted on March 2, 2010. The qualifying emergency preparedness exercise was conducted on December 9, 1980.

DHS/FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise. In the State of Michigan, the risk counties of Allegan, Berrien, and Van Buren

participated in cooperation with various state government and non-profit agencies. In the State

of Indiana, the risk counties of Elkhart, La Porte and St. Joseph participated in cooperation with

various state government and non-profit agencies.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this

responsibility by volunteering to provide vital emergency services to their communities.

Cooperation and teamwork on the part of all the participants were evident during this exercise.

This Final Report contains the evaluation of the biennial exercise and the evaluation of the following out-of-sequence interviews and activities:

• Protective Actions for Schools (EV-2) for the Covert Public School District Monitoring and Decontamination of evacuees and emergency workers

Monitoring and Decontamination of emergency worker's equipment

Public Registration

Congregate Care Center

Medical Service Drills (MS-1) at the Covert Fire Department and South Haven Community

Hospital 6 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Except where noted in this report, the State and local organizations demonstrated knowledge of and adequately implemented their emergency response plans and procedures.

No Deficiencies were identified for the State of Michigan or for Allegan, Berrien, and Van Buren Counties during this exercise.

There was one Area Requiring Corrective Action (ARCA) identified for the State of Michigan during this exercise. The ARCA identified for the State of Michigan was Number 44-12-4c1-A-

01 under Criterion 4.c.1 - The laboratory is capable of performing required radiological analyses

to support protective action decisions. The Michigan Department of Environmental Quality (MDEQ) Radiological Protection Laboratory (RPL) personnel participating in the demonstration

were not familiar with the operation of the laboratory's radiation survey meters. The

laboratory's sample preparation equipment was incapable of either processing the volume of

materials required or preventing contamination. The sample processing area lacked adequate

bench space for handling larger bulk samples and the entire area would have rapidly become

contaminated. The laboratory's counting equipment was not operable and the laboratory staff

was unable to acquire data for analysis and/or demonstrate data analysis. The laboratory's

record keeping system was not capable of managing the anticipated sample volume and the

sample storage area lacked shelves, storage cabinets and various other resources needed to

manage the volume of samples that would be anticipated in the event of an actual radiological

emergency at the PNPP. The laboratory staff's ability to effectively coordinate with Federal or

private-sector participants was not demonstrated. FEMA Region V and FEMA Headquarters are

scheduled to conduct one or more health physics / radiological laboratory operations Staff Assist

Visits (SAVs) with the Michigan Department of Environmental Quality (MDEQ) Radiological

Protection Laboratory (RPL). The redemonstration of these criteria will occur in conjunction

with the DC Cook Plume Exposure Pathway exercise in June, 2013.

There were no prior ARCAs identified for the State of Michigan during the March 2, 2010, Palisades Nuclear Power Plant REP exercise which required redemonstration during this

exercise.There were three planning issues identified for the State of Michigan during the March 1, 2011, D. C. Cook Nuclear Plant REP exercise, two of which were closed during this exercise.

Planning issues 15-11-3a1-P-02 under Protective Action Implementation, Emergency Worker 7 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Exposure Control Implementation, Criterion 3.a.1 - OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the

plans/procedures; and planning issue 15-11-6a1-P-01 under Support Operations/Facilities, Reception Center Operations, Criterion 6.a.1 - The reception center facility has appropriate

space, adequate resources, and trained personnel to provide monitoring, decontamination, and

registration of evacuees; have been closed.

Planning issue 15-11-4a3-P-03, under Field Measurement and Analysis, Field Team Operations, Criterion 4.a.3 - Ambient radiation measurements are made and recorded at appropriate

locations, and radioiodine and particulate samples are collected. Teams will move to an

appropriate low-background location to determine whether any significant (as specified in the

plan and/or procedures) amount of radioactivity has been collected on the sampling media, was

not satisfactorily redemonstrated. This issue could not be closed because the 6 cubic-foot sample

volume included in the field monitoring SOP had not been changed to meet the required 10 cubic-foot sample volume for 1E-7 µCi/cc sensitivity. Planning issue 44-12-4a3-P-02 describes

the observations from this exercise.

There were two Criteria that were not demonstrated by the State of Michigan during this exercise. The Michigan Department of Environmental Quality (MDEQ) Radiological Protection

Laboratory (RPL) was not able to demonstrate criterion 1.e.1, Equipment, maps, displays, dosimetry, KI, and other supplies are sufficient to support emergency operations; or criterion

3.a.1, OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure

to emergency workers in accordance with the plans/procedures. Emergency workers periodically

and at the end of each mission read their dosimeters and record the readings on the appropriate

exposure record or chart. Appropriate record-keeping of the administration of KI for emergency

workers is maintained. FEMA Region V and FEMA Headquarters are scheduled to conduct one

or more health physics / radiological laboratory operations Staff Assist Visits (SAVs) with the

Michigan Department of Environmental Quality (MDEQ) Radiological Protection Laboratory (RPL). The redemonstration of these criteria will occur in conjunction with the DC Cook Plume

Exposure Pathway exercise in June, 2013.

There were no ARCAs or Planning Issues identified for Van Buren County during this exercise.

There were no ARCA or Planning Issues identified for Allegan County during this exercise.

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There was one Planning Issue identified for Allegan County during the March 2, 2010, Palisades Nuclear Power Plant REP exercise, Planning Issue Number 44-10-6a1-P-03, which was closed

during this exercise.

There were no ARCA or Planning Issues identified for Berrien County during this exercise.

No Deficiencies were identified for the State of Indiana or for Elkhart, Kosciusko, La Porte and St. Joseph Counties during this exercise.

There was one ARCA identified for the State of Indiana during this exercise. The ARCA identified for the State of Indiana was Number 44-12-3a1-A-03 under Criterion 3.a.1 - OROs

issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to

emergency workers in accordance with the plans/procedures. The dosimetry coordinator at the

Forward Operations Center was not familiar with dosimeter charging and the dosimeters that

were initially issued were not charged and ready for use. The Field Sampling Team (FST)

dosimetry brief was incomplete and did not adequately address either administrative reporting or

turn-back values for either radiological accumulated dose or exposure rate. The DRDs issued to

emergency workers were not capable of recording the exposure levels initially discussed in the

FST pre-deployment briefing. Permanent record dosimeters (PRDs) are required for every

emergency worker entering a potentially contaminated area, but were not mentioned in either the

plans or briefings and were not available for issue. Additionally, some emergency workers who

received the dosimetry information were unfamiliar with their equipment and unable to

demonstrate adequate knowledge regarding the use of their dosimetry. Although, not technically

required for the ingestion exposure pathway, emergency workers received no information

regarding the use and purpose of Potassium Iodide (KI). In an actual radiological emergency, there would probably have had questions that if not satisfactory answered could impede

emergency response operations. This criterion will be redemonstrated at a date to be coordinated

upon completion of the corrective actions identified in this report.

There were no Planning Issues identified for the State of Indiana during this exercise.

There were six Criteria that were not demonstrated by the State of Indiana during this exercise.

Exercise participants at the Indiana State Emergency Operations Center (EOC) were not

provided sufficient information and opportunity to demonstrate criteria 1.c.1 - Key personnel

with leadership roles for the ORO provide direction and control to that part of the overall 9 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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response effort for which they are responsible; 2.d.1 - Radiological consequences for the ingestion pathway are assessed and appropriate PADs are made based on the ORO planning

criteria; 3.e.1 - The ORO demonstrates the availability and appropriate use of adequate

information regarding water, food supplies, milk, and agricultural production within the

ingestion exposure pathway emergency planning zone for implementation of protective actions;

3.e.2 - Appropriate measures, strategies, and pre-printed instructional material are developed for

implementing PADs for contaminated water, food products, milk, and agricultural production;

and 3.f.1 - Decisions regarding controlled reentry of emergency workers and relocation and

return of the public during the post-emergency phase are coordinated with appropriate

organizations and implemented. Additionally, criteria 2.a.1 - OROs use a decision-making

process, considering relevant factors and appropriate coordination, to ensure that an exposure

control system, including use of KI, is in place for emergency workers, including provisions to

authorize radiation exposure in excess of administrative limits or PAGs, was not demonstrated at

the Forward Operations Center. These criteria will be redemonstrated at a date to be coordinated

upon completion of the corrective actions identified in this report.

There were no prior ARCAs or Planning Issues identified for the State of Indiana which required redemonstration during this exercise.

INTRODUCTION - EXERCISE BASIS

On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. DHS/FEMA's activities are conducted pursuant to 44

Code of Federal Regulations (CFR) Parts 350 "Review and Approval of State and Local

Radiological Emergency Plans and Preparedness", 351 "Radiological Emergency Planning and

Preparedness" and 352 "Commercial Nuclear Power Plants: Emergency Preparedness Planning."

These regulations are a key element in the Radiological Emergency Preparedness (REP) Program

that was established following the Three Mile Island Nuclear Station accident in March 1979.

The FEMA Rule 44 CFR 350 establishes the policies and procedures for DHS/FEMA's initial and continued approval of State and local governments' radiological emergency planning and

preparedness for commercial nuclear power plants. This approval is contingent, in part, on State

and local governments' participation in joint exercises with licensees.

DHS/FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities 10 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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include the following:

Taking the lead in offsite emergency planning and in the review and evaluation of RERPs and procedures developed by State and local governments; Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local

governments; Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal

Register, Vol. 58, No. 176, September 14, 1993); and Coordinating the activities of Federal agencies with responsibilities in the radiological emergency planning process:

- U.S. Department of Agriculture;

- U.S. Department of Commerce;

- U.S. Department of Energy;

- U.S. Department of Health and Human Services;

- U.S. Department of the Interior;

- U.S. Department of Transportation;

- U.S. Environmental Protection Agency;

- U.S. Food and Drug Administration; and

- U.S. Nuclear Regulatory Commission.

Representatives of these agencies serve on the DHS/FEMA Region V Regional Assistance Committee (RAC), which is chaired by DHS/FEMA.

Formal submission of the RERPs for the Palisades Nuclear Power Plant to FEMA Region V by the State of Michigan and involved local jurisdictions occurred on December 9, 1980. Formal

approval of these RERPs was granted by FEMA on July 6, 1982, under 44 CFR 350.

A REP Full-Participation Plume Exposure Pathway Exercise was conducted on October 29, 2012, and evaluated by DHS/FEMA to assess the capabilities of State and local offsite

emergency preparedness organizations in implementing their RERPs and procedures to protect 11 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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the public health and safety during a radiological emergency involving the Palisades Nuclear Power Plant. The purpose of this exercise report is to present the exercise results and findings on

the performance of the Offsite Response Organizations (ORO) during a simulated radiological

emergency.

The findings presented in this report are based on the evaluations of the Federal evaluation team, with final determinations made by the DHS/FEMA Region V RAC Chairperson, and approved

by the DHS/FEMA Headquarters.

The criteria utilized in the FEMA evaluation process are contained in:

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

November 1980; FEMA "Radiological Emergency Preparedness Manual," April 2012.

FEMA "Radiological Emergency Preparedness: Exercise Evaluation Methodology; Notice" as published in the Federal Register Notice, Vol. 67, No. 80, dated April 25, 2002.

Section 1 of this report, entitled "Exercise Overview", presents information pertaining to the team that planned and coordinated the exercise. This section also provides listing of all

participating jurisdictions and functional entities that were evaluated.

Section 2 of this report, entitled "Exercise Design Summary", contains the purpose and design of the exercise, a description of the plume pathway EPZ and presents basic information and data

relevant to the exercise scenario.

Section 3 of this report, entitled "Analysis of Capabilities," presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in

a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all

Deficiencies and ARCAs (if any) assessed during this exercise, recommended corrective actions, and the State and local governments' schedule of corrective actions, if applicable, for each

identified exercise issue; and (2) descriptions of unresolved ARCAs assessed during previous

exercises and the status of the OROs' efforts to resolve them.

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Section 4 of this report, entitled "Conclusion" presents the DHS/FEMA summary of overall exercise conduct and results as evaluated against the requirements of 44 CFR 350.

EMERGENCY PLANNING ZONE (EPZ) DESCRIPTION

The Palisades Nuclear Power Plant is a single unit pressurized water reactor with a net capacity of 805 megawatts. The facility owned and operated by Entergy Nuclear Operations, Incorporated, commenced commercial operation in December 1971. Lake Michigan is the

cooling water source for the plant.

The plant is located in northwestern Van Buren County, Michigan, on the shore of Lake Michigan, approximately five miles south-southwest of South Haven. The 10-mile Plume

Exposure Pathway EPZ of the Palisades Nuclear Power Plant encompasses parts of Allegan, Berrien, and Van Buren Counties, with the major portion of the zone falling within Van Buren

County. Based on 2000 Census data, the total plume pathway EPZ permanent population is

33,027 persons. In Michigan, the 50-mile Ingestion Exposure Pathway EPZ of the Palisades

Nuclear Power Plant encompasses parts of Allegan, Bary, Berrien, Cass, Kalamazoo, Kent, Ottawa, St. Joseph and Van Buren Counties. In Indiana, the 50-mile Ingestion Exposure

Pathway EPZ of the Palisades Nuclear Power Plant encompasses parts of Elkhart, La Porte and

St. Joseph Counties.

The 10-mile Plume Exposure Pathway EPZ is comprised of five Protective Action Areas (PAAs), numbered 1 to 5, with PAAs 1, 2, and 3 being located within Van Buren County only;

PAA 4 is located within both Allegan and Van Buren Counties; and PAA 5 is located within

both Berrien and Van Buren Counties. Per the 2000 Census, the permanent population of PAA 1

is 2,001. The permanent population of PAA 2 is 1,939. The permanent population of PAA 3 is

2,360. The permanent population of PAA 4 is 10,283. The permanent population of PAA 5 is

4,308.Approximately 50 percent of the 10-mile Plume Exposure Pathway EPZ lies within Lake Michigan. The lake attracts a large number of vacationers during the summer. The area includes

various summer resorts, which offer camping facilities, light housekeeping cottages, tourist's

attractions, and the Van Buren State Park. The City of South Haven, with a tourism based

economy, is located five miles north of the plant. The population varies from summer to winter 13 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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months.Agricultural use of the land includes seasonal fresh fruit and vegetable farming and processing.

Peak agricultural use takes place during the spring, summer, and fall months.

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SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Palisades Nuclear Power Plant Type of Exercise Ingestion Exercise Date October 30, 2012 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness

Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership William King

Exercise RAC Chairperson

DHS/FEMA Radiological Assistance Committee, Chairman

536 South Clark Street

Chicago, Illinois, 60605

312-408-5575

William.King5@fema.dhs.gov Dwaine Warren Exercise Director

DHS/FEMA Region V

Supervisory REP Team Leader

536 S. Clark Street 15 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Chicago , Illinois, 60605 312-408-5342

dwaine.warren@fema.dhs.gov Karl Rabenhorst Palisades Site Specialist/Exercise Coordinator

DHS/FEMA Technical Hazards Program Specialist

536 S. Clark Street

Chicago, Illinois, 60605

312-408-5516

karl.rabenhorst@fema.dhs.gov John Simpson Indiana Site Specialist

DHS/FEMA Technical Hazards Specialist

536 S. Clark Street

Chicago, Illinois, 60605

312-408-5242

john.simpson3@fema.dhs.gov Thomas Higginbotham State Lead Controller

Michigan State Police Emergency Management & Homeland Security Division Michigan

State Police

Manager, Radiological Emergency Preparedness Unit

4000 Collins Road

Lansing, Michigan, 48910

517-333-5035

HiginbothamT@Michigan.gov 16 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Tonya Nobach Planning & Program Development Section

Michigan State Police Emergency Management & Homeland Security Division

Radiological Emergency Preparedness Unit

4000 Collins Road

Lansing, Michigan, 48910

517-333-5028

NobachT@michigan.gov Jim Fontaine Lead Offsite Planner

Entergy Corporation

Sr. Emergency Planning Coordinator

27780 Blue Star Memorial Highway

Covert, Michigan, 49043

269-764-2587

nbrott@entergy.com John Copeland Indiana State Exercise Director

Indiana Department of Homeland Security

Radiological Specialist / Radiological Emergency Preparedness Program Coordinator

302 West Washington Street

Indianapolis, Indiana, 46204

317-232-3980

jocopeland@dhs.in.gov 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Palisades

Nuclear Power Plant exercise:

State Jurisdictions Michigan Department of Environmental Quality 17 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Michigan Department of Health Michigan Department of Transportation

Michigan Governor's Representitive

Michigan State Attorney General's Office

Michigan State Fire Marshall Representitive

Michigan State Police

Michigan State Police Emergency Management Homeland Security Division

Michigan State Supreme Court

Indiana Department of Homeland Security

Indiana Governor's Office

Indiana Department of Environmental Management

Indiana State Police

Indiana National Guard

Indiana State Department of Health

Indiana State Department of Agriculture

Indiana Department of Natural Resources

Indiana Department of Transportation

Indiana Department of Administration

Indiana Board of Animal Health

Indiana Utility Regulatory Commission

Office of the Indiana State Chemist Risk Jurisdictions Allegan County Emergency Management Agency

Allegan County Health Department

Allegan County Hotline Representitive

Allegan County Public Information Officer

Allegan County Radiological Defense (RADEF)

Allegan County Sheriff's Department (911 operators)

Allegan County Sheriff's Department

Berrien County Chief Executive

Berrien County Chief of Staff

Berrien County Emergency Management

Berrien County Health Department

Berrien County Hotline Representitive 18 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Berrien County Public Information Officer Berrien County Public Safety Communications Dispatch Center

Berrien County Sheriff's Department

Berrien County Sheriff's Department Hazardous Materials Unit

Covert Fire & EMS

Covert School District

South Haven School District

Van Buren County Office of Domestic Preparedness

Van Buren Sheriff's Office

Van Buren County Health Department

Van Buren Independent School District

Van Buren County Hotline Representitive Support Jurisdictions Elkhart County Emergency Mangement

Elkhart County Health Department

Kosciuko County Emergency Management

LaPorte County Emergency Management

LaPorte County Hazardous Materials Team

South Bend Fire Department

St. Joseph County Emergency Management

St. Joseph County Health Department Private Organizations Allegan County RACES

American Red Cross

American Red Cross, Kalamazoo Chapter

Area Agency on Aging Region IV

Black River Amateur Radio Club

Palisades Nuclear Power Plant

Radio Amatuer Civil Emergency Services (RACES)

Salvation Army

South Haven Community Hospital

WSJM Radio Station

Purdue Extension Services Federal Jurisdictions 19 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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US Nuclear Regulatory Commission US Department of Energy

US Environmental Protection Agency

US Department of Agriculture

US Department of Transportation

US Coast Guard 20 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design The DHS/FEMA Region V Office evaluated the Palisades Nuclear Power Plant (PNPP)

Radiological Emergency Preparedness (REP) Full-Participation Plume and Ingestion Exposure

Pathway Exercises conducted on October 29 and 30, 2012, to assess the capabilities of local

emergency preparedness organizations in implementing their Radiological Emergency Response

Plans (RERP) and procedures to protect the public health and safety during a radiological

emergency involving the PNPP. The purpose of this report is to present the results and findings

on the performance of the Offsite Response Organizations (OROs) during a simulated

radiological emergency.

2.2 Exercise Objectives, Capabilities and Activities Exercise objectives and identified Capabilities/REP Criteria selected to be demonstrated are

discussed in Appendix E "Exercise Plan."

2.3 Scenario Summary Appendix F "Scenario Details," contains a summary of the Exercise Scenarios, a simulated

sequence of events that was used as the basis for invoking emergency response actions by Offsite

Response Organizations (OROs) in the Palisades Nuclear Power Plant (PNPP) REP Full-

Participation Plume Exposure Pathway exercise on October 29, 2012. The PNPP REP Ingestion

Exposure Pathway exercise on October 30, 2012 was conducted as a Table-Top Exercise with

concurrent drills conducted by Off-Site Response Organizations (OROs).

This exercise scenario was submitted by the State of Michigan and Entergy Corporation and accepted by DHS/FEMA Region V on October 19, 2012.

During the exercise, in addition to information and data provided through the PNPP onsite scenario, controllers from the State of Michigan provided "inject messages" containing scenario

events and/or relevant data to those persons or locations who would normally receive notification

of such events. These inject messages were the method used for invoking additional specific

response actions by OROs.

21 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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The details of the scenario are included in Appendix F "Scenario Details."

22 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the October 29 and 30, 2012, REP Full-Participation

Plume and Ingestion Exposure Pathway Exercises conducted to test the offsite emergency

response capabilities of State and local governments in the EPZ surrounding the PNPP.

Each jurisdiction and functional entity was evaluated based on its demonstration of exercise criteria delineated in REP Program Manual dated April, 2012. Detailed information on the

exercise criteria and the extent-of-play agreements used in this exercise are found in Appendix E

"Exercise Plan" of this report.

Presented below are definitions of the terms used in this report relative to the criteria demonstration status:

M - Met: The status of a REP exercise Evaluation Area Criterion indicating that the participating Offsite Response Organization (ORO) demonstrated all demonstration criteria for

the Evaluation Area Criterion to the level required in the extent-of-play agreement with no

Deficiencies or ARCAs assessed in the current exercise and no unresolved prior ARCAs.

D - Deficiency: An observed or identified inadequacy of organizational performance in an

exercise that could cause a finding that offsite emergency preparedness is not adequate to

provide reasonable assurance that appropriate protective measures can be taken in the event of a

radiological emergency to protect the health and safety of the public living in the vicinity of a

nuclear power plant.

A - Area Requiring Corrective Action (ARCA) - An observed or identified inadequacy of

organizational performance in an exercise that is not considered, by itself, to adversely impact

public health and safety. Listing of the demonstrated exercise criteria under which one or more

ARCAs was/were assessed during the current exercise or ARCAs assessed during prior exercises

remain unresolved. Included is a description of any ARCAs assessed during this exercise and

the recommended corrective action to be demonstrated before or during the next biennial

exercise.

P - Plan Issue - An observed or identified inadequacy in the ORO's emergency plan or

implementing procedures, rather than in the ORO's performance.

N - Not Demonstrated - Exercise criteria that were not demonstrated as scheduled during this 23 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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exercise and the reason(s) they were not demonstrated.

Prior ARCAs - Resolved - Descriptions of ARCAs assessed during previous exercises that were

resolved and the corrective actions demonstrated, in this exercise.

Prior ARCAs - Unresolved - Descriptions of ARCAs assessed during prior exercises that were

not resolved in this exercise. Included is the reason the ARCA remains unresolved and

recommended corrective actions to be demonstrated before or during the next exercise.

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of all exercise

criteria from REP Program Manual, dated April, 2012, which were scheduled for demonstration

during this exercise by all participating jurisdictions and functional entities. The criterion status

box is blank if it was not scheduled for demonstration.

This subsection provides information on the evaluation of each participating jurisdiction and functional entity in a jurisdiction-based, issues-only format.

The DHS has developed a standardized system for numbering exercise issues. This system is used to achieve consistency in numbering exercise issues among DHS Regions and site-specific

exercise reports within each Region. It also is used to expedite tracking of exercise issues on a

nationwide basis.

The identifying number of Deficiencies, ARCAs, and Plan Issues includes the following elements, with each element separated by a hyphen (-).

Plant Site Identifier - A two-digit number, corresponding to the Utility Billable Plant Site Code (44 for Palisades Nuclear Power Plant).

Exercise Year - The last two digits of the year the exercise was conducted.

Criterion Number - An alpha and two-digit number corresponding to the criteria numbers in the

six Exercise Evaluation Areas described in REP Program Manual, dated April, 2012, Radiological Emergency Preparedness Exercise Manual.

Issue Classification Identifier - (D = Deficiency, A = ARCA, P = Plan Issue).

Exercise Identification Number - A separate two or three-digit indexing number assigned to

each issue identified in the exercise.

24 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Table 3.1 - Summary of Exercise Evaluation (5 pages)

DATE: 2012-10-30 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated MI-INP MI-SEOC MI-SEOC TSG

MI-FTC-MDOT Coloma MI-FTC MDOT Coloma-DosBrief-EW/TACP MI-MDEQ FMT1-MDOT Coloma MI-MDEQ FMT2-MDOT Coloma MI-MDEQ FMT3-MDOT Coloma MI-MDEQ RadProLab---

MI-MSP-TACP - MDOT Coloma MI-EOC ALG-StLias--

Emergency Operations ManagementMobilization1a1MMFacilities1b1 Direction and Control1c1MMM Communications Equipment1d1MMMMMMMM Equipment and Supplies to Support Operations1e1MMMMMMNMM Protective Action Decision MakingEW Exposure Control Decisions2a1MM PARs2b1MM PADs2b2MM PADs for Disabled/Functional Needs2c1M Ingestion PADs2d1M RRR Decisions2e1M Protective Action ImplementationEW Exposure Control Implementation3a1MMMMNM KI Public/Institutionalized3b1M PAD Implementation Disabled/Functional Needs3c1 PAD Implementation Schools3c2 TACP Establishment3d1MM Impediments3d2 Implement Ingestion PADs3e1M Coordination of RRR Decisions3e2M Coordination of RRR Decisions3f1M Field Measurement and AnalysisRESERVED4a1 Field Team Management4a2MMM Field Team Operations4a3MP Field Team Sampling4b1MMMMM Laboratory Operations4c1A Emergency Notification and Public InfoInitial Alert & Notification5a1MMM RESERVED5a2 Backup Alert & Notification5a3 Exception Area Alerting5a4 Subsequent Information & Instructions5b1MMM 25 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Support Operations/FacilitiesReception Center Operations6a1MEW Monitoring & Decontamination6b1M Congregate Care6c1 Contaminated Injured Transport & Care6d1 26 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/5)

DATE: 2012-10-30 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated MI-EOC BER-StLias--

MI-EOC VAN-StLiai--

MI-JIC---PNPP

MI-JIC--RumCon-PNPP MI- Berrien Springs HS--EvMD-MDEQ Rep-MI-Covert FIRE/EMS-MS1T-MDEQ Rep-MI- Fennville HS--EvMD-MDEQ Rep-MI-South Haven CH-MS-1F-MDEQ Rep MI-Watervliet HS--EWMDEqV-MDEQ Rep IN-IDHS Watch---

IN-SEOC---

Emergency Operations ManagementMobilization1a1MMMFacilities1b1M Direction and Control1c1MMMN Communications Equipment1d1MMMMMM Equipment and Supplies to Support Operations1e1MMMMMM Protective Action Decision MakingEW Exposure Control Decisions2a1 PARs2b1 PADs2b2 PADs for Disabled/Functional Needs2c1 Ingestion PADs2d1N RRR Decisions2e1 Protective Action ImplementationEW Exposure Control Implementation3a1MMMMM KI Public/Institutionalized3b1 PAD Implementation Disabled/Functional Needs3c1 PAD Implementation Schools3c2 TACP Establishment3d1 Impediments3d2 Implement Ingestion PADs3e1N Coordination of RRR Decisions3e2N Coordination of RRR Decisions3f1N Field Measurement and AnalysisRESERVED4a1 Field Team Management4a2 Field Team Operations4a3 Field Team Sampling4b1 Laboratory Operations4c1 Emergency Notification and Public InfoInitial Alert & Notification5a1MM RESERVED5a2 Backup Alert & Notification5a3 Exception Area Alerting5a4 Subsequent Information & Instructions5b1MMM 27 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Support Operations/FacilitiesReception Center Operations6a1MMEW Monitoring & Decontamination6b1M Congregate Care6c1 Contaminated Injured Transport & Care6d1 28 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/5)

DATE: 2012-10-30 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated IN-JIC---SEOC IN-FOC--Bremen-IN--FST 1-Bremen-

IN--FST 2-Bremen-IN--FST 3-Bremen-IN-ISDH RadLab---

ALG-INP---

ALG-EOC---

ALG---DosBrief-EW/TACP ALG---TACP-ALG--JIC Rep--PNPP Emergency Operations ManagementMobilization1a1MMMFacilities1b1 Direction and Control1c1MMM Communications Equipment1d1MMMMMMMM Equipment and Supplies to Support Operations1e1MMMMMMMMM Protective Action Decision MakingEW Exposure Control Decisions2a1N PARs2b1 PADs2b2 PADs for Disabled/Functional Needs2c1M Ingestion PADs2d1 RRR Decisions2e1 Protective Action ImplementationEW Exposure Control Implementation3a1AMMMMMMM KI Public/Institutionalized3b1M PAD Implementation Disabled/Functional Needs3c1M PAD Implementation Schools3c2M TACP Establishment3d1MM Impediments3d2M Implement Ingestion PADs3e1 Coordination of RRR Decisions3e2 Coordination of RRR Decisions3f1 Field Measurement and AnalysisRESERVED4a1 Field Team Management4a2 Field Team Operations4a3 Field Team Sampling4b1MMM Laboratory Operations4c1M Emergency Notification and Public InfoInitial Alert & Notification5a1M RESERVED5a2 Backup Alert & Notification5a3 Exception Area Alerting5a4 Subsequent Information & Instructions5b1MMM Support Operations/FacilitiesReception Center Operations6a1 EW Monitoring & Decontamination6b1M Congregate Care6c1 Contaminated Injured Transport & Care6d1 29 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Table 3.1 - Summary of Exercise Evaluation (Continued. page 4/5)

DATE: 2012-10-30 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated ALG- Fennville HS--EvMDR-ALG-Fennville HS--EvMDV-ALG- Fennville JHS--CCC-

BER-INP---

BER-EOC---

BER---DosBrief-EW/TACP BER---TACP-BER--JIC REP--PNPP BER-Berrien Springs HS--EvMDR-BER-Berrien Springs HS--CCC-BER-Watervliet HS--EWMD-Emergency Operations ManagementMobilization1a1MMFacilities1b1 Direction and Control1c1M Communications Equipment1d1MMMMMMM Equipment and Supplies to Support Operations1e1MMMMMMM Protective Action Decision MakingEW Exposure Control Decisions2a1 PARs2b1 PADs2b2 PADs for Disabled/Functional Needs2c1M Ingestion PADs2d1 RRR Decisions2e1 Protective Action ImplementationEW Exposure Control Implementation3a1MMMMM KI Public/Institutionalized3b1M PAD Implementation Disabled/Functional Needs3c1M PAD Implementation Schools3c2M TACP Establishment3d1MM Impediments3d2M Implement Ingestion PADs3e1 Coordination of RRR Decisions3e2 Coordination of RRR Decisions3f1 Field Measurement and AnalysisRESERVED4a1 Field Team Management4a2 Field Team Operations4a3 Field Team Sampling4b1 Laboratory Operations4c1 Emergency Notification and Public InfoInitial Alert & Notification5a1M RESERVED5a2 Backup Alert & Notification5a3 Exception Area Alerting5a4 Subsequent Information & Instructions5b1MM Support Operations/FacilitiesReception Center Operations6a1MMM EW Monitoring & Decontamination6b1M 30 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Congregate Care6c1MMContaminated Injured Transport & Care6d1 31 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Table 3.1 - Summary of Exercise Evaluation (Continued. page 5/5)

DATE: 2012-10-30 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated BER-Watervliet HS--EWMDVEq-VAN-INP---

VAN-EOC---

VAN---DosBrief-EW/TACP VAN---TACP-VAN--JIC REP-- PNPP VAN-EAS-WSJM---

VAN--Covert Fire/EMS-MS1T-VAN--Covert PS-EV2-VAN-Mattawan HS--CCC-VAN-South Haven CH-MS1F-Emergency Operations ManagementMobilization1a1MMFacilities1b1 Direction and Control1c1MM Communications Equipment1d1MMMMMMMMM Equipment and Supplies to Support Operations1e1MMMMMMMM Protective Action Decision MakingEW Exposure Control Decisions2a1 PARs2b1 PADs2b2 PADs for Disabled/Functional Needs2c1M Ingestion PADs2d1 RRR Decisions2e1 Protective Action ImplementationEW Exposure Control Implementation3a1MMMMMM KI Public/Institutionalized3b1M PAD Implementation Disabled/Functional Needs3c1M PAD Implementation Schools3c2MM TACP Establishment3d1MM Impediments3d2M Implement Ingestion PADs3e1 Coordination of RRR Decisions3e2 Coordination of RRR Decisions3f1 Field Measurement and AnalysisRESERVED4a1 Field Team Management4a2 Field Team Operations4a3 Field Team Sampling4b1 Laboratory Operations4c1 Emergency Notification and Public InfoInitial Alert & Notification5a1MM RESERVED5a2 Backup Alert & Notification5a3 Exception Area Alerting5a4 Subsequent Information & Instructions5b1MM Support Operations/FacilitiesReception Center Operations6a1 EW Monitoring & Decontamination6b1M 32 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Congregate Care6c1MContaminated Injured Transport & Care6d1MM 33 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.3.3 Criteria Evaluation Summaries 3.3.1 Indiana Jurisdictions 3.3.1.1 State of Indiana - IDHS Watch Officer In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 State of Indiana - State Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.d.1, 1.e.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: 1.c.1, 2.d.1, 3.e.1, 3.e.2, 3.f.1.

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 State of Indiana - Joint Information Center - SEOC In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.c.1, 1.d.1, 1.e.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None 34 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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g.a.b.PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 State of Indiana - Forward Operations Center - Bremen In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 6.b.1.

AREAS REQUIRING CORRECTIVE ACTION: 3.a.1.

ISSUE NO.: 44-12-3a1-A-03

CRITERION: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the

plans/procedures. Emergency workers periodically and at the end of each mission

read their dosimeters and record the readings on the appropriate exposure record or

chart. Appropriate record-keeping of the administration of KI for emergency workers

is maintained.

CONDITION: The dosimetry coordinator was not familiar with dosimeter charging and the dosimeters that were initially issued were not charged and ready for use. The

Field Sampling Team (FST) dosimetry brief was incomplete and did not adequately

address either administrative reporting or turn-back values for either radiological

accumulated dose or exposure rate. The DRDs issued to emergency workers were

not capable of recording the exposure levels initially discussed in the FST pre-

deployment briefing. Permanent record dosimeters (PRDs) are required for every

emergency worker entering a potentially contaminated area, but were not mentioned

in either the plans or briefings and were not available for issue. Additionally, some

emergency workers who received the dosimetry information were unfamiliar with

their equipment and unable to demonstrate adequate knowledge regarding the use of

their dosimetry. Although, not technically required for the ingestion exposure

pathway, emergency workers received no information regarding the use and purpose

of Potassium Iodide (KI). In an actual radiological emergency, there would probably

have had questions that if not satisfactory answered could impede emergency

response operations.

POSSIBLE CAUSE: The dosimetry coordinator did not have the knowledge, skills and abilities required to adequately perform assigned duties. The FOC, FST plans 35 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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c.and procedures and dosimetry briefing check list did not include any discussion of accumulated radiological dose or exposure rate turn-back values, permanent record

dosimeters, or Potassium Iodide (KI). FOC and FST equipment had not been

adequately maintained and inventoried, as evidenced by missing dosimetry and FST

sample collection equipment.

REFERENCE:

NUREG-0654/FEMA REP 1 K.3.a Each organization shall make provision for 24-hour-per-day capability to determine

the doses received by emergency personnel involved in any nuclear accident, including volunteers. Each organization shall make provisions for distribution of

dosimeters, both self-reading and permanent record devices.

EFFECT: Emergency workers could have been deployed into radiologically contaminated areas with direct reading dosimeters that were not charged and could

not indicate their actual exposure. Emergency workers who were issued properly

zeroed 0-200mR direct reading dosimeters did not know what their accumulated dose

or exposure rate turn-back values were. Without permanent record dosimeters it

would be impossible to identify an emergency worker's actual accumulated exposure

in the event that their 0-200mR direct reading dosimeter went off-scale between

hourly readings. Although, not technically required for the ingestion exposure

pathway, a complete lack of information regarding the use and purpose of Potassium

Iodide (KI) could impede emergency response operations in an actual radiological

emergency.

RECOMMENDATION: Provide additional Dosimetry Coordinator and Field Sampling Team training, conduct more frequent inventories and inspections of

radiological response team equipment and supplies, and conduct more frequent drills

to retain adequate skill levels. Revise relevant plans, procedures and briefing guides

to include a thorough discussion of accumulated radiological dose and exposure rate

administrative reporting and turn-back values, permanent record dosimeters, and

Potassium Iodide (KI). This criterion will be redemonstrated at a date to be

coordinated upon completion of the corrective actions identified above.

DEFICIENCY: None 36 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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d.e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.PLAN ISSUES: None NOT DEMONSTRATED: 2.a.1.

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.1.5 State of Indiana - Indiana Field Sampling Team 1 - Bremen In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.1.6 State of Indiana - Indiana Field Sampling Team 2 - Bremen In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.1.7 State of Indiana - Indiana Field Sampling Team 3 - Bremen In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None 37 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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f.g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 3.3.1.8 State of Indiana - Indiana State Department of Health Radiochemistry Laboratory In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.e.1, 3.a.1, 4.c.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2 Michigan Jurisdictions

3.3.2.1 State of Michigan - Initial Notification Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 State of Michigan - State Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 2.c.1, 3.b.1, 3.d.1, 3.e.2, 3.f.1, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None 38 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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f.g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 State of Michigan - SEOC Technical Support Group In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 2.b.1, 2.b.2, 2.d.1, 2.e.1, 3.e.1, 4.b.1, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.4 State of Michigan - Field Team Center - MDOT Coloma In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 4.a.2, 4.b.1, 6.a.1, 6.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.5 State of Michigan - Field Team Center MDOT Coloma - Dosimetry Briefing -

Emergency Worker / Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.e.1, 3.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None 39 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.PRIOR ISSUES - UNRESOLVED: None 3.3.2.6 State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 1 MDOT Coloma In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 4.a.2, 4.a.3, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.7 State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 2 - MDOT Coloma In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 4.a.2, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: 4.a.3.

ISSUE NO.: 44-12-4a3-P-02

CRITERION: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to

an appropriate low-background location to determine whether any significant (as

specified in the plan and/or procedures) amount of radioactivity has been collected on

the sampling media.

CONDITION: This issue is a carry-over for the State of Michigan from the March 1, 2011 DC Cook 2011 Exercise: Issue Number: 15-11-4a3-P-03. Criterion: 4.a.3 could

not be closed during this exercise because 6 cubic-foot sample volume included in the field monitoring SOP had not been changed to meet the required 1E-7 µCi/cc

sensitivity.

40 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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e.f.

g.a.b.

c.

d.POSSIBLE CAUSE: Planners did not address the FEMA REP-2 requirement for minimum air sample volume of 10 cubic feet and the requirement for purging the air

sampler cartridge prior to analysis.

REFERENCE:

The Michigan Department of Environmental Quality, 2010 Health Physics Response Team (HPRT) Standard Operating Procedure (SOP, Page 3, indicates that the HPRT is to "run the sampler long enough to process 6 cu. ft. of air

through the sample." The Michigan Department of Environmental Quality, 2010 Health Physics Response Team (HPRT) SOP, page 4, does not indicate the need to purge the air sampler prior

to analysis.

EFFECT: The counting system may not be sensitive enough to detect radioiodines aslow as 1E-7 µCi/cc when the total volume collected is less than 10 cubic feet. The

net count may cause a gross overestimation of the calculated thyroid dose due to

presence of noble gases remaining in the sample cartridge if air sample is not purged

prior to analysis.

RECOMMENDATION: Increase the sample time to five minutes. Purge the air sampler for a few seconds in a low background area prior to analysis.

NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.8 State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 3 MDOT Coloma In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 4.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None 41 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

e.f.

g.a.b.NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.9 State of Michigan - Michigan Department of Environmental Quality Radiological Protection Laboratory In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: None AREAS REQUIRING CORRECTIVE ACTION: 4.c.1.

ISSUE NO.: 44-12-4c1-A-01

CRITERION: The laboratory is capable of performing required radiological analyses to support PADs.

CONDITION: The laboratory personnel participating in the demonstration were unfamiliar with the operation of the laboratory's radiation survey meters. The

laboratory's sample preparation equipment was incapable of either processing the

volume of materials required or preventing contamination. The sample processing

area lacked adequate bench space for handling larger bulk samples and the entire area

would have rapidly become contaminated. The laboratory's counting equipment was

not operable and the laboratory staff was unable to acquire data for analysis and/or

demonstrate data analysis. The laboratory's record keeping system was not capable

of managing the anticipated sample volume and the sample storage area lacked

shelves, storage cabinets and various other resources needed to manage the volume

of samples that would be anticipated in the event of an actual radiological emergency

at the PNPP. The laboratory staff's ability to effectively coordinate with Federal or

private-sector participants was not demonstrated.

POSSIBLE CAUSE: The laboratory personnel did not have the knowledge, skills and abilities required to adequately perform their assigned duties.

The laboratory facilities and equipment did not provide the resources required for the staff to perform their assigned duties.

42 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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REFERENCE:

NUREG-0654/FEMA-REP-1 (C. 3; J.11)

C. Emergency Response Support and Resources

Planning Standard

Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site

Emergency Operations Facility have been made, and other organizations capable of

augmenting the planned response have been identified.

3. The offsite response organization shall identify radiological laboratories and their general capabilities and expected availability to provide radiological monitoring

and analyses services which can be used in an emergency.

J. Protective Response

Planning Standard

A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective

actions during an emergency, consistent with Federal guidance, are developed and in

place, and protective actions for the ingestion exposure pathway EPZ appropriate to

the locale have been developed.

11. The offsite response organization shall specify the protective measures to be used for the ingestion pathway, including the methods for protecting the public from

consumption of contaminated foodstuffs. This shall include criteria for deciding

whether dairy animals shall be put on stored feed. The offsite plan shall identify

procedures for detecting contamination, for estimating the dose commitment

consequences of uncontrolled ingestion, and for imposing protection procedures such

as impoundment, decontamination, processing, decay, product diversion, and

preservation. Maps for recording survey and monitoring data, key land use data (e.g.,

farming), dairies, food processing plants, water sheds, water supply intake and 43 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

treatment plants and reservoirs shall be maintained. Provisions for maps showing detailed crop information may be by including reference to their availability and

location and a plan for their use. The maps shall start at the facility and include all of

the 50-mile ingestion pathway EPZ. Up-to-date lists of the name and location of all

facilities which regularly process milk products and other large amounts of food or

agricultural products originating in the ingestion pathway Emergency Planning Zone, but located elsewhere, shall be maintained.

EFFECT: The laboratory personnel participating in the demonstration failed to adequately survey the simulated incoming samples and would have contaminated

themselves and the incoming sample receipt area. The laboratory's sample

preparation area and equipment were incapable of either processing the types and

volume of materials required such that the entire sample processing area, as well as

the samples, would have rapidly become contaminated. The laboratory's counting

equipment was inoperable and the laboratory staff was unable to acquire data

required to perform data analysis. The laboratory's record keeping system was not

capable of managing the anticipated sample volume and the sample storage area

lacked the various resources needed to manage the volume of samples that would be

anticipated in the event of an actual radiological emergency at the PNPP. The

laboratory staff's ability to effectively coordinate with Federal or private-sector

participants was not demonstrated.

RECOMMENDATION: Coordinate with FEMA Region V and FEMA Headquarters to conduct one or more health physics / radiological laboratory operations Staff

Assist Visits (SAVs) as necessary to:

Conduct a thorough assessment of the Radiological Protection Laboratory's entire operation to identify and replace obsolete, inadequate and/or defective facilities, equipment, processes, procedures and other infrastructure used to receive, process, track, analyze, store and report the results of radiological laboratory analyses in a

timely and accurate manner.

Provide thorough training for the Radiological Protection Laboratory staff regarding the proper use of personal protective equipment, dosimetry, radiological survey

equipment, radiological sample processing equipment, radiological sample tracking, 44 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

c.d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.analysis and storage, and reporting the of radiological laboratory analyses in a timely and accurate manner.

The Michigan Department of Environmental Quality (MDEQ) Radiological Protection Laboratory (RPL) will redemonstrate criteria 1.e.1, 3.a.1 and 4.c.1 in

conjunction with the DC Cook Plume Exposure Pathway exercise in June, 2013.

DEFICIENCY: None PLAN ISSUES: None

NOT DEMONSTRATED: 1.e.1, 3.a.1.

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.10 State of Michigan - Michigan State Police - Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.11 State of Michigan - Allegan County Emergency Operations Center - State Liaison In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.c.1, 1.d.1, 1.e.1, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 45 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.2.12 State of Michigan - Berrien County Emergency Operations Center - State Liaison In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.c.1, 1.d.1, 1.e.1, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.13 State of Michigan - Van Buren County Emergency Operations Center - State Liaison In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.c.1, 1.d.1, 1.e.1, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.14 State of Michigan - Joint Information Center - PNPP In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 46 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.2.15 State of Michigan - Joint Information Center - Rumor Control - PNPP In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.16 State of Michigan - Berrien Springs High School - Evacuee Monitoring and Decontamination - MDEQ Representative In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.17 State of Michigan - Covert Fire/EMS - Medical Service - Transportation - MDEQ Representative In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.e.1, 3.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 47 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.2.18 State of Michigan - Fennville High School - Evacuee Monitoring and Decontamination - MDEQ Representative In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.19 State of Michigan - South Haven Community Hospital - Medical Service - Facility -

MDEQ Representative In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.e.1, 3.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.2.20 State of Michigan - Watervliet HS - Emergency Worker Monitoring and Decontamination of Equipment and Vehicles - MDEQ Representative In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 3.a.1, 6.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 48 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3 Risk Jurisdictions 3.3.3.1 Allegan County - Initial Notification Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.2 Allegan County - Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.3 Allegan County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.e.1, 3.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 49 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.4 Allegan County - Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.5 Allegan County - Joint Information Center Representative - PNPP In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.6 Allegan County - Fennville High School - Evacuee Monitoring, Decontamination and Registration In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 50 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.7 Allegan County - Fennville High School - Evacuee Vehicle Monitoring &

Decontamination In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.8 Allegan County - Fennville Jr High School - Congregate Care Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 6.c.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.9 Berrien County - Initial Notification Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 51 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.10 Berrien County - Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.11 Berrien County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.e.1, 3.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.12 Berrien County - Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 52 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.13 Berrien County - Joint Information Center County Representative - PNPP In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.14 Berrien County - Berrien Springs High School - Evacuee Monitoring, Decontamination & Registration In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.15 Berrien County - Berrien Springs High School - Congregate Care Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 6.c.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 53 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.16 Berrien County - Watervliet High School - Emergency Worker Monitoring &

Decontamination In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 6.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.17 Berrien County - Watervliet High School - Emergency Worker Vehicle &

Equipment Monitoring & Decontamination In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 6.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.18 Van Buren County - Initial Notification Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 54 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

_____________________________________________________________________

a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.19 Van Buren County - Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.20 Van Buren County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.e.1, 3.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.21 Van Buren County - Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 3.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 55 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.22 Van Buren County - Joint Information Center Representative - PNPP In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.23 Van Buren County - Emergency Alert System Radio Station WSJM In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 5.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.24 Van Buren County - Covert Fire/EMS - Medical Service - Transportation In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 6.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 56 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.a.b.

c.

d.

e.

f.

g.3.3.3.25 Van Buren County - Covert Public Schools - Evacuation School In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.26 Van Buren County - Mattawan High School - Congregate Care Center In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.c.1, 1.d.1, 1.e.1, 6.c.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 3.3.3.27 Van Buren County - South Haven Community Hospital - Medical Service - Facility In summary, the status of DHS/FEMA criteria for this location is as follows:

MET: 1.d.1, 1.e.1, 3.a.1, 6.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None

DEFICIENCY: None

PLAN ISSUES: None

NOT DEMONSTRATED: None

PRIOR ISSUES - RESOLVED: None

PRIOR ISSUES - UNRESOLVED: None 57 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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SECTION 4: CONCLUSION Based on the results of the October 30 and 31, 2012 exercises, the offsite radiological emergency response plans and preparedness for the State of Michigan and affected local jurisdictions, site-

specific to the Palisades Nuclear Power Plant, can be implemented and are adequate to provide

reasonable assurance that appropriate measures can be taken offsite to protect the health and

safety of the public in the event of a radiological emergency at the site. Therefore, the Title 44

CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness

for the State of Michigan site-specific to the Palisades Nuclear Power Plant, remain in effect.

58 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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APPENDIX A: IMPROVEMENT PLAN 59 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Issue Number: 44-12-3a1-A-03Criterion: 3a1 ISSUE: The dosimetry coordinator was not familiar with dosimeter charging and the dosimeters that were initially issued were not charged and ready for use. The Field Sampling Team (FST) dosimetry brief was

incomplete and did not adequately address either administrative reporting or turn-back values for either radiological

accumulated dose or exposure rate. The DRDs issued to emergency workers were not capable of recording the

exposure levels initially discussed in the FST pre-deployment briefing. Permanent record dosimeters (PRDs) are

required for every emergency worker entering a potentially contaminated area, but were not mentioned in either the

plans or briefings and were not available for issue. Additionally, some emergency workers who received the

dosimetry information were unfamiliar with their equipment and unable to demonstrate adequate knowledge

regarding the use of their dosimetry. Although, not technically required for the ingestion exposure pathway, emergency workers received no information regarding the use and purpose of Potassium Iodide (KI). In an actual

radiological emergency, there would probably have had questions that if not satisfactory answered could impede

emergency response operations.

RECOMMENDATION:

Provide additional Dosimetry Coordinator and Field Sampling Team training, conduct more frequent inventories and inspections of radiological response team equipment and supplies, and

conduct more frequent drills to retain adequate skill levels. Revise relevant plans, procedures and briefing guides to

include a thorough discussion of accumulated radiological dose and exposure rate administrative reporting and

turn-back values, permanent record dosimeters, and Potassium Iodide (KI). This criterion will be redemonstrated at

a date to be coordinated upon completion of the corrective actions identified above.

CORRECTIVE ACTION DESCRIPTION:

1. Issue Number: 44-12-3a1-A-03 Corrective Action

Description:

The Indiana Department of Homeland Security will be providing additional training to the Dosimetry Coordinator and Forward Operations Center personnel on the use and issuance of dosimetry. The

position checklist and guide for the Dosimetry Coordinator will also be updated with more specific directions the

issuing of dosimetry, checking dosimeters, and items necessary to brief sampling team personnel on.

The Ingestion Pathway Plan and Forward Operations Center operating guides will also be revised to include turn-back values, permanent record dosimeters, and Potassium Iodide (KI).

These items will also be incorporated into sampling team and Forward Operations Center position's training. This

criterion will be redemonstrated via a drill conducted at the Indiana Government Center during the summer of

2013.2. Not demonstrated criteria 1c1, 2d1, 3e1, 3e2 & 3f1

Correction Action

Description:

The Indiana Department of Homeland Security will be providing additional training and seminars to the members of Indiana's Emergency Operations Center Policy Group on their roles and

responsibilities during an ingestion pathway response. This will include hosting a seminar for the agency heads and

representatives, as well as, reviewing the position checklists in the Ingestion Pathway Plan. These criteria will be

demonstrated via a table-top exercise conducted during the summer of 2013.

3. Not demonstrated criteria 2a1

Corrective Action

Description:

The Indiana Department of Homeland Security will be reviewing the current exposure control system that is in place, adding provisions for the consideration of Potassium Iodide (KI), and

provisions to authorize radiation exposure in excess of administrative limits or protective action guides. Forward

Operations Center personnel and sampling team personnel will be trained on this system and its limits in

conjunction with the 3a1, dosimetry, training. This criterion will be demonstrated, in conjunction with the

redemonstration of criterion 3a1, via a drill conducted at the Indiana Government Center in the summer of 2013.

c. Schedule of Events March 12, 2013: Meet with FEMA Region V staff to discuss redemonstrations

Mid-May 2013: EOC Policy Group Seminar/Training

Mid-June 2013: FOC Training on dosimetry and radiation exposure system

July 10, 2013: 3a1 Redemonstration, 2a1 Demonstration, 1c1, 2d1, 3e1, 3e2 & 3f1 Demonstration CAPABILITY:

Weapons of Mass Destruction (WMD) and Hazardous

Materials (HazMat) Response and Decontamination PRIMARY RESPONSIBLE AGENCY:

Indiana Department of Homeland Security CAPABILITY ELEMENT:

Systems and Equipment START DATE:

2012-11-15 60 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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AGENCY POC:

Laura Dresen 317-234-6510 ESTIMATED COMPLETION DATE:

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Issue Number: 44-12-4a3-P-02Criterion: 4a3 ISSUE: This issue is a carry-over for the State of Michigan from the March 1, 2011 DC Cook 2011 Exercise:

Issue Number: 15-11-4a3-P-03. Criterion: 4.a.3 could not be closed during this exercise because 6 cubic-foot sample volume included in the field monitoring SOP had not been changed to meet the required 1E-7 µCi/cc

sensitivity.

RECOMMENDATION:

Increase the sample time to five minutes. Purge the air sampler for a few seconds in a low background area prior to analysis.

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CORRECTIVE ACTION DESCRIPTION:

Planning Issue 15-11-4a3-P-03 under Criterion 4.a.3 (Cook 2011) and Planning Issue 44-12-43a-P-02 under Criterion 4.a.3 (Palisades 2012): This issue is a carryover for the

State of Michigan from the March 1, 2011, DC Cook 2011 Exercise. Criterion 4.a.3 could not be closed because

the 6 cubic foot sample volume included in the field monitoring Standard Operating Procedure (SOP) has not been changed to meet the required 1E-7 µCi/cc sensitivity; FEMA's recommendation for this planning issue is as

follows: "Increase the sample to five minutes. Purge the air sampler for a few seconds in a low background area prior to analysis." MDEQ addresses this issue as follows:

Condition:

The condition cited in planning issue 15-11-4a3-P-03 is that the Health Physics Response Team (HPRT) SOP specified air sampler volume to be collected does not meet the required minimum volume of 10 cubic feet necessary to detect the presence of radioiodine concentrations as low as 1E-7 µCi/cc. In the reference portion of the

D.C. Cook After Action Report (ML11200A171), specific referencing of FEMA REP-2, revision 2, Appendix D (page D-13) is given stating that "A minimum sample volume of 10 cubic feet should be collected." However, the

requirement of NUREG-0654/FEMA REP-1 is the ability to measure radioiodine concentrations as low as 1E-7

µCi/cc regardless of total volume of sample taken.

The State of Michigan HPRT collects a volume of 6 cubic feet and maintains the capability to detect radioiodineconcentrations within the minimum requirement of 1E-7 µCi/cc. The lower volume reduces the amount of time the

HPRT spends in the plume and is consistent with the principles of As Low As Reasonably Achievable (ALARA).

Justification:

The methodology given in FEMA REP-2, revision 2, Appendix D (page D-11) is that the minimum detectable air sample concentration may be expressed as:

MDL C = ----------

V*CY Where:

C = concentration of radioiodines in µCi/cc MDL = minimum detectable level = 2*sqrt(B) (for instruments with digital readout displays)

B = background in counts per minute (cpm)

V = volume of the sample in cc CY = instrument counting yield in cpm/µCi FEMA REP-2 gives a sample calculation using this equation in which the following are used:

B = background count rate of 600 cpm V = 10 cubic feet of air = 2.8317E5 cc CY = 90 cps/µCi of I-131 = 5400 cpm/µCi Then:

2*sqrt(600)C = ---------------------------- = 3.2E-8 µCi/cc.

(2.8317E5)(5400)

This example gives a result well below the minimum requirement for detectability. According to FEMA REP-2, the CY value used in this example is "reasonable for a pancake type GM detector." A series of calculations have been

done using the above formula and the assumptions made for a pancake style GM detector but changing the sample

volume and background counts:

For 4 cubic feet (1.133E5 cc) and 600 cpm background:

2*sqrt(600)C = --------------------------- = 8.01E-8 µCi/cc.

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(1.133E5)(5400)

For 4 cubic feet (1.133E5 cc) and 60 cpm background:

2*sqrt(60)C = --------------------------- = 2.53E-8 µCi/cc.

(1.133E5)(5400)

For 6 cubic feet (1.699E5 cc) and 600 cpm background:

2*sqrt(600)C = -------------------------- = 5.34E-8 µCi/cc.

(1.699E5)(5400)

For 6 cubic feet (1.699E5 cc) and 60 cpm background:

2*sqrt(60)C = -------------------------- = 1.69E-8 µCi/cc.

(1.699E5)(5400)

All of these calculations show the NUREG-0654/FEMA REP-1 requirement of being able to detect radioiodines toa concentration as low as 1E-7 µCi/cc can easily be met. The State of Michigan HPRTs use digital survey meters

with pancake style GM detectors to count air samples in the field. A typical pancake style GM detector in the State

of Michigan will read background at approximately 60 cpm, so those computations should be used. While it is

theoretically possible to meet the requirement with a sample volume as low as 4 cubic feet of air, Michigan HPRTs

collect 6 cubic feet.

In addition, HPRTs will use silver zeolite cartridges for air sampling in an actual emergency (charcoal cartridges are used for a drill/exercise). According to a statement in the frequently asked questions to the FEMA REP

Program manual (question #58) and an article in the 2006 Radiation Safety Journal, purging is not required when

using silver zeolite. Because silver zeolite has a strong affinity for polar molecules and I-131 is polar whereas

noble gases are non-polar, the retention efficiency of silver zeolite cartridges for radioactive iodine can exceed 99.9

percent while retention of radioactive noble gases does not exceed 0.02 percent (Wang, 2006).

The Radiological Emergency Preparedness Unit of the MDEQ requests that planning issues 15-11-4a3-P-03 and 44-12-43a-P-02 be closed based on the above documentation.

References FEMA REP Program Manual; April 2012

FEMA REP-2. Attachment D

Wang WH, Matthews KL. Simulating Gaseous I-131 Distribution in a Silver Zeolite Cartridge Using Sodium

Iodide Solution. RSJ vol. 20, suppl 2; May 2006.

Based upon the documentation provided, the Michigan Field Monitoring Teams using a digital survey meter (e.g.

Eberline E-600) with a 2 mg/cm2 density pancake G-M detector (e.g. HP-260), and accumulating a 4 to 6 cubic

foot radioiodine air sample with a silver zeolite cartridge (6 cu ft specified in the procedures), and counting the

cartridge in a low background area (e.g.60-600 cpm) WILL meet the NUREG-0654 requirement of being able to detect a radioiodine sample of 1E-7 µCi/cc.

FEMA concurs with the State of Michigan's analysis and Planning Issues 15-11-4a3-P-03 and 44-12-4a3-P-02 are hereby closed.

CAPABILITY:

Weapons of Mass Destruction (WMD) and Hazardous

Materials (HazMat) Response and Decontamination PRIMARY RESPONSIBLE AGENCY:

Michigan Department of Environmental Quality CAPABILITY ELEMENT:

Planning START DATE:

2012-11-15 AGENCY POC:

Ken Yale, Chief, Radiological Protection Section 517-

373-4797 ESTIMATED COMPLETION DATE:

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Issue Number: 44-12-4c1-A-01Criterion: 4c1 ISSUE: The laboratory personnel participating in the demonstration were unfamiliar with the operation of the laboratory's radiation survey meters. The laboratory's sample preparation equipment was incapable of either

processing the volume of materials required or preventing contamination. The sample processing area lacked

adequate bench space for handling larger bulk samples and the entire area would have rapidly become

contaminated. The laboratory's counting equipment was not operable and the laboratory staff was unable to

acquire data for analysis and/or demonstrate data analysis. The laboratory's record keeping system was not capable

of managing the anticipated sample volume and the sample storage area lacked shelves, storage cabinets and

various other resources needed to manage the volume of samples that would be anticipated in the event of an actual

radiological emergency at the PNPP. The laboratory staff's ability to effectively coordinate with Federal or

private-sector participants was not demonstrated.

RECOMMENDATION:

Coordinate with FEMA Region V and FEMA Headquarters to conduct one or more health physics / radiological laboratory operations Staff Assist Visits (SAVs) as necessary to:

Conduct a thorough assessment of the Radiological Protection Laboratory's entire operation to identify and replace obsolete, inadequate and/or defective facilities, equipment, processes, procedures and other infrastructure used to

receive, process, track, analyze, store and report the results of radiological laboratory analyses in a timely and

accurate manner.

Provide thorough training for the Radiological Protection Laboratory staff regarding the proper use of personal protective equipment, dosimetry, radiological survey equipment, radiological sample processing equipment, radiological sample tracking, analysis and storage, and reporting the of radiological laboratory analyses in a timely

and accurate manner.

The Michigan Department of Environmental Quality (MDEQ) Radiological Protection Laboratory (RPL) will redemonstrate criteria 1.e.1, 3.a.1 and 4.c.1 in conjunction with the DC Cook Plume Exposure Pathway exercise in

June, 2013.

CORRECTIVE ACTION DESCRIPTION:

On February 11 and l2, 2013, MDEQ completed a Staff Assistance Visit (SAV) with FEMA Headquarters Health Physics staff. During the SAV, a thorough assessment of

the RPL's entire operation was conducted. Among the issues identified were process issues including sample

receiving, hot/cold zone identification, and work flow issues. Also identified was the lack of an established system

to identify and track radiological samples.

MDEQ has also completed its own review and re-assessment of the RPL's plans and procedures and has made several changes, including the issues identified above. A complete rewrite of the RPL Standard Operating Guide (SOG) has been undertaken.

During the SAV, FEMA Headquarters HP staff provided insight and training concerning issues identified during the Palisades exercise and during the SAV. Among the issues discussed (trained on) included dosimetry issuance, proper use of radiological survey equipment, sample processing, overall operation of the RPL, and reporting of the

RPL's analyses in a timely manner. Training was also given regarding hot/cold zone identification and work flow

issues.MDEQ plans to complete at least two in-depth training sessions with RPL personnel to better acquaint staff with issues including (but not limited to):

Sample Receipt Sample Identification

Sample Tracking

Contamination Control

Waste Handling

Chain-of-Custody

Sample Preparation

Sample Analysis

Sample Results

Results Conmmnication

Sample Storage

Plans and Procedural Changes The MDEQ will redemonstrate the listed criteria in June, 2013. An Extent-of-Play specific to the RPL will be drafted for this demonstration and be submitted to FEMA for approval.

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CAPABILITY:

Laboratory Testing PRIMARY RESPONSIBLE AGENCY:

Michigan Department of Environmental Quality CAPABILITY ELEMENT:

Systems and Equipment START DATE:

2012-11-15 AGENCY POC:

Ken Yale, Chief, Radiological Protection Section 517-373-4797 ESTIMATED COMPLETION DATE:

2013-05-31 66 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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APPENDIX B: EXERCISE TIMELINE Table 1, on the following page, presents the times at which key events and activities occurred during the Palisades Nuclear Power Plant REP Partial Participation Plume Exposure Pathway

exercise conducted on March 2, 2010. Also included are times notifications were made to the

participating jurisdictions/functional entities.

Table 1 - Exercise Timeline DATE: 2012-10-30, SITE: Palisades Nuclear Power Plant, MI Emergency Classification Level or Event Time Utility Declared MI-SEOC ALG-EOC---

BER-EOC---

VAN-EOC---

Unusual EventAlert0816082808280828 Site Area Emergency10001011101510151015 General Emergency11281134115111511151 Simulated Rad. Release Started0816

Simulated Rad. Release TerminatedFacility Declared Operational0932090309180908 Declaration of State of Emergency1018101610181002 Exercise Terminated1400140114011400 Early Precautionary Actions:100010281025 1st Protective Action Decision:1145115511551151

1st Siren Activation 11541st EAS or EBS Message1212 2nd Protective Action Decision:1336133513431337 2nd Siren Activation13491346 2nd EAS or EBS Message13491350

3rd Protective Action Decision:

3rd Siren Activation

3rd EAS or EBS Message

4th Protective Action Decision:

4th Siren Activation

4th EAS or EBS Message

5th Protective Action Decision:

5th Siren Activation

5th EAS or EBS Message

6th Protective Action Decision:

6th Siren Activation

6th EAS or EBS Message KI Administration Decision:1145115511581151 67 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel that evaluated the Palisades Nuclear Power Plant REP Partial Participation Plume Exposure Pathway Exercise on March 2, 2010. The list includes the

evaluation team leadership and all evaluators. The organization each evaluator represents is

indicated by the following abbreviations:

Department of Homeland Security / Federal Emergency Management Agency (DHS/FEMA)

Title Name Organizati on Radiological Assistance Committee, Chairman William E. King DHS/FEMA

Exercise Director Dwaine Warren DHS/FEMA

Senior Specialist Gary Naskrent DHS/FEMA

Site Specialist Karl Rabenhorst DHS/FEMA

Team Leader - Michigan James King DHS/FEMA

Team Leader - Indiana John Simpson DHS/FEMA

Team Leader - Van Buren County David Ortman DHS/FEMA

Team Leader - Berrien County Edward Golinski DHS/FEMA

Team Leader - Allegan County Clinton Crackel DHS/FEMA ICF Consulting Regional Coordinator John Wills ICF 68 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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DATE: 2012-10-30, SITE: Palisades Nuclear Power Plant, MILOCATIONEVALUATORAGENCYState of Michigan - Initial Notification PointRobert NoeckerICFIState of Michigan - State Emergency Operations CenterEdward Diaz Robert Noecker FEMA RV ICFIState of Michigan - SEOC Technical Support GroupMichael HoweFEMA HQ State of Michigan - Field Team Center - MDOT ColomaPatrick TaylorICFI

State of Michigan - Field Team Center MDOT Coloma - Dosimetry Briefing - Emergency Worker / Traffic and Access Control PointJohn WillsICFI State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 1 MDOT ColomaRichard SmithICF State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 2 - MDOT ColomaRichard WattsICFI State of Michigan - Michigan Department of Environmental Quality Field Monitoring Team 3 MDOT ColomaJohn WillsICFI State of Michigan - Michigan Department of Environmental Quality Radiological Protection LaboratoryPaul WardFEMA HQ State of Michigan - Michigan State Police - Traffic and Access Control PointFrank CordaroICFI State of Michigan - Allegan County Emergency Operations Center -

State LiaisonCarolyn SturghillFEMA RV State of Michigan - Berrien County Emergency Operations Center -

State LiaisonTodd GemskieFEMA RV State of Michigan - Van Buren County Emergency Operations Center- State LiaisonMichael HenryICFIState of Michigan - Joint Information Center - PNPPPaul Nied John D. Simpson ICFI FEMA RIVState of Michigan - Joint Information Center - Rumor Control - PNPPPaul NiedICFI

State of Michigan - Berrien Springs High School - Evacuee Monitoring and Decontamination - MDEQ RepresentativeRichard SmithICF State of Michigan - Covert Fire/EMS - Medical Service -

Transportation - MDEQ RepresentativeDaniel KanakaresFEMA RV State of Michigan - Fennville High School - Evacuee Monitoring and Decontamination - MDEQ RepresentativeSonia EischenICFI State of Michigan - South Haven Community Hospital - Medical Service - Facility - MDEQ RepresentativeChristopher BelloneFEMA RV State of Michigan - Watervliet HS - Emergency Worker Monitoring and Decontamination of Equipment and Vehicles - MDEQ

RepresentativeRichard WattsICFIState of Indiana - IDHS Watch OfficerKent ToschICFIState of Indiana - State Emergency Operations CenterKarl Rabenhorst Roy Smith FEMA Reg V ICFIState of Indiana - Joint Information Center - SEOC*John D. SimpsonFEMA RIV State of Indiana - Forward Operations Center - BremenJohn ZeidlerICFI State of Indiana - Indiana Field Sampling Team 1 - BremenSonia EischenICFI State of Indiana - Indiana Field Sampling Team 2 - BremenWes RyalsICFI State of Indiana - Indiana Field Sampling Team 3 - BremenPaul WardFEMA HQ

State of Indiana - Indiana State Department of Health Radiochemistry LaboratoryKent ToschICFIAllegan County - Initial Notification PointDebra SchneckICFI 69 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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Allegan County - Emergency Operations CenterGary Bolender Carolyn Sturghill ICFI FEMA RV Allegan County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control PointGary BolenderICFIAllegan County - Traffic and Access Control PointDebra SchneckICFIAllegan County - Joint Information Center Representative - PNPPJohn D. SimpsonFEMA RIV

Allegan County - Fennville High School - Evacuee Monitoring, Decontamination and Registration Debra Schneck Carolyn Sturghill ICFI FEMA RV Allegan County - Fennville High School - Evacuee Vehicle Monitoring & DecontaminationSonia EischenICFIAllegan County - Fennville Jr High School - Congregate Care CenterDaniel KanakaresFEMA RVBerrien County - Initial Notification PointDon DanielFEMA Region VBerrien County - Emergency Operations CenterTodd Gemskie James Greer FEMA RV ICFI Berrien County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control PointJames GreerICFIBerrien County - Traffic and Access Control PointDon DanielFEMA Region V Berrien County - Joint Information Center County Representative -

PNPPJohn D. SimpsonFEMA RIV Berrien County - Berrien Springs High School - Evacuee Monitoring, Decontamination & RegistrationKent ToschICFI Berrien County - Berrien Springs High School - Congregate Care CenterChristopher BelloneFEMA RV Berrien County - Watervliet High School - Emergency Worker Monitoring & DecontaminationRichard WattsICFI Berrien County - Watervliet High School - Emergency Worker Vehicle & Equipment Monitoring & DecontaminationFrank CordaroICFIVan Buren County - Initial Notification PointDanny LoomisICFIVan Buren County - Emergency Operations CenterMichael Henry Karl Rabenhorst

William Vocke ICFI FEMA Reg V

ICFI Van Buren County - Dosimetry Briefing - Emergency Worker / Traffic and Access Control PointDanny LoomisICFIVan Buren County - Traffic and Access Control PointDanny LoomisICFIVan Buren County - Joint Information Center Representative - PNPPJohn D. SimpsonFEMA RIV Van Buren County - Emergency Alert System Radio Station WSJMWilliam VockeICFI

Van Buren County - Covert Fire/EMS - Medical Service -

TransportationDaniel KanakaresFEMA RVVan Buren County - Covert Public Schools - Evacuation SchoolPaul NiedICFIVan Buren County - Mattawan High School - Congregate Care CenterDanny Loomis William Vocke ICFI ICFI Van Buren County - South Haven Community Hospital - Medical Service - FacilityChristopher BelloneFEMA RV

• Team Leader 70 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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APPENDIX D: ACRONYMS AND ABBREVIATIONSAcronymMeaningACPAccess Control Point ALSAdvanced Life Support AMSAerial Monitoring System ARCAmerican Red Cross ARCAArea Requiring Corrective Action BCEMABerrien County Emergency Management Agency BPBlood Pressure BSHSBerrien Springs High School CCCCongregate Care Center CDCCentral Dispatch Center CDECommitted Dose Equivalent CEOChief Executive Officer CERTCitizens Emergency Response Team CFCorrection Factor CPMCounts Per Minute CPSCovert Public School DCDosimetry Coordinator DRDDirect Read Dosimeters EASEmergency Alert System ECLEmergency Classification Level EDEmergency Department EMAEmergency Management Agency EMADEmergency Management Agency Director EMCEmergency Management Coordinator EMDEmergency Management Director EMSEmergency Medical Services EOCEmergency Operations Center EOFEmergency Operations Facility EOPEmergency Operations Plan EPAEnvironmental Protection Agency EPDElectronic Personal Dosimeter EPZEmergency Planning Zone ESFEmergency Support Function EWEmergency Worker 71 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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FEMAFederal Emergency Management AgencyFMTField Monitoring Team FOCForward Operations Center FSTField Sampling Team FTCField Team Center FTCCField Team Center Coordinator GEGeneral Emergency GISGeographic Information Systems GMGeiger Mueller GPSGlobal Positioning System HERNHospital Emergency Radio Network HIPAHealth Information Privacy Act HPRTHealth Physics Response Team HPSHealth Physics Support HSIPHomeland Security Information Program ICIncident Commander IMIncident Manager INPInitial Notification Point ISDIntermediate School District ISPIndiana State Police ITInformation Technology JICJoint Information Center LEINLaw Enforcement Information Network MDCMinimum Detectable Concentration MDTMobile Data Terminal MIOCMichigan Intelligence Operations Center MSPMichigan State Police NPPNuclear Power Plant NRCNuclear Regulatory Commission OROOffsite Response Organization OSLOptically Stimulated Luminescence OSLDOptically Stimulated Luminescent Dosimeter PAAProtective Action Areas PAGProtective Action Guide PAOProtective Action Order PIBPublic Information Brochure PIOPublic Information Officer PNPPPalisades Nuclear Power Plant PPEPersonal Protective Equipment PRCPublic Reception Center 72 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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PRDPermanent Record DosimeterRACRegional Assistance Committee RACESRadio Amateur Civil Emergency Services RDLRadiological Decontamination Leader REARadiation Emergency Area REPRadiological Emergency Preparedness RPLRadiological Protection Laboratory RSORadiation Safety Officer SAESite Area Emergency SEOCState Emergency Operations Center SHHSSouth Haven Health System SOPStandard Operating Procedure TACPTraffic Access Control Point TCPTraffic Control Point TEDETotal Effective Dose Equivalent TSGTechnical Support Group UHFUltra High Frequency USCGUnited States Coast Guard VBCVan Buren County VBISDVan Buren Intermediate School District VHFVery High Frequency WANWide Area Network WDCWorker Decontamination Center 73 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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APPENDIX E: EXERCISE PLAN This appendix lists the exercise criteria, which were scheduled for demonstration in the Palisades Nuclear Power Plant Radiological Emergency Preparedness Partial Participation Plume

Exposure Pathway Exercise on March 2, 2010, and the offsite extent-of-play agreement accepted

by DHS/FEMA Region V on January 29, 2010. The exercise criteria, contained in the FEMA

"Radiological Emergency Preparedness Exercise Evaluation Methodology; Notice," as published

in the Federal Register Notice/Vol. 67, dated April 25, 2002, represent a functional translation of

the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Rev1, "Criteria

for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness

in Support of Nuclear Power Plants," November 1980. Because the exercise criteria are intended

for use at all nuclear power plant sites, and because of variations among offsite plans and

procedures, an extent-of-play agreement is prepared by the State and accepted by DHS/FEMA to

provide evaluators with guidance on expected actual demonstration of the criteria.

Exercise Criteria and Extent-of-Play Agreements Listed on the following pages are the specific radiological emergency preparedness criteria that

were scheduled for demonstration during this exercise.

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EXTENT-OF-PLAY AGREEMENTS PALISADES 2012 PPX & IPX TABLE OF FACILITY DEMONSTRATIONS2012 Palisades REP Exercise Facility Demonstration -FinalRev: October 19, 2012 STATE FACILITIES FACILITY ADDRESS CONTACT ACTIVATION CONTROLLERSEOC4000 Collins RoadLansing, MI 48910Thomas Higinbotham517-242-4726In sync with scenario.Thomas Higinbotham517-242-4726Tonya Nobach517-242-6505Day 2 Ingestion Pathway TabletopDiagnostic Center for Population and Animal Health Room 1014125 Beaumont Rd Lansing, MI 48910Thomas Higinbotham517-242-4726In sync with scenario.Thomas Higinbotham517-242-4726Field Team CenterColoma Maintenance Garage 3880 Red Arrow Hwy.Benton Harbor, MI 49022 Ken Yale517-242-8565In sync with scenario and out-of-sync with ingestion portion of exercise.Kari Day734-476-8241Access Control SEOCTonya Nobach517-242-6505In sync with scenarioTonya Nobach517-242-6505Access Control PointFTC Coloma Maintenance Garage 3880 Red Arrow Hwy.Benton Harbor, MI 49022 Ken Yale517-242-8565In sync with scenario.Kari Day734-476-8241DEQ Lab815 Filley StLansing MIBob Skowronek517-327-2615October 29, 2012 9:00am N/A 75 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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PALISADES EMERGENCY FACILITIES FACILITY ADDRESS CONTACT PERSON ACTIVATION TIME CONTROLLERJIC330 W.Main St.Benton Harbor, MI 49022Nicole Lisabeth517-242-3810In sync with scenario.Lori Hornbeck517-242-6509Public Inquiry Control Center330 W. Main St.Benton Harbor, MI 49022Mark Savage 269-764-2333269-303-3481 (c)In sync with scenario.Lori Hornbeck517-242-6509INITIAL NOTIFICATION POINTS FACILITY ADDRESS CONTACT PERSON ACTIVATION TIME CONTROLLERState Of MichiganMSP Operations333 S. Grand AveLansing, MI 48913Lieutenant on dutyIn sync with scenarioVan Buren County Van Buren County Sheriff Dept Central Dispatch205 S Kalamazoo St. Paw Paw, MI 49079Officer on dutyIn sync with scenarioAllegan County Allegan County Sheriff Dept Central Dispatch3271 122nd Avenue Allegan, MI 49022Officer ondutyIn sync with scenarioBerrien County Berrien County Gov't Complex, Public Safety Comm. Dispatch Cntr.2100 E. Empire Ave., Benton Harbor, MI 49022Officer on dutyIn sync with scenario 76 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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ALLEGAN COUNTY FACILITY ADDRESS CONTACT PERSON ACTIVATION TIME CONTROLLEREOC3271 122nd AvenueAllegan, MI 49010Scott Corbin 269-673-0571In sync with scenarioAmanda Bresler517-242-2527Dosimetry3271 122nd AvenueAllegan, MI 49010Scott Corbin 269-673-0571-OfficeIn sync with scenarioAmanda Bresler517-242-2527Emergency Worker DecontaminationN/AN/AN/AN/APublic Reception/ Decontamination CenterFennville High School5 West Memorial Drive Fennville, MI 49408Scott Corbin 269-673-0571-OfficeOctober 30, 2012 6pmTonya Nobach517-242-6505Public Congregate Care CenterFennville High School5 West Memorial Drive Fennville, MI 49408Scott Corbin 269-673-0571-OfficeOctober 30, 2012 6pmTonya Nobach517-242-6505Access Control Point3271 122nd AvenueAllegan, MI 49010Law Enforcement Representative in the EOC.In sync with scenarioAmanda Bresler517-242-2527MS-1See Van Buren N/A N/A N/A 77 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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BERRIEN COUNTY FACILITY ADDRESS CONTACT PERSON ACTIVATION TIME CONTROLLER EOCBerrien County Gov't Complex,2100 E. Empire Ave., Benton Harbor, MI. 49022Corey Burks269-983-7111, ext 4916In sync with scenarioCarol Wolfinger517-648-8598DosimetryEOC interview RADPRO Representative in the EOC.In sync with scenarioCarol Wolfinger517-648-8598Emergency Worker and Vehicle DecontaminationWatervliet HS450 East Saint Joseph StreetWatervliet, MI 49098Corey Burks269-983-7111, ext 4916Tuesday, October 30, 2012 7 pmTonya Nobach517-242-6505Public Reception/Decontamination CenterBerrien Springs HS1 Sylvester AvenueBerrien SpringsCorey Burks269-983-7111, ext 4916Monday, October 29, 2012 7 pmTonya Nobach517-242-6505Public Congregate Care CenterBerrien Springs HS1 Sylvester AvenueBerrien SpringsCorey Burks269-983-7111, ext 4916Monday, October 29, 2012 4pmTonya Nobach517-242-6505EV-2 School InterviewN/AN/AN/AN/AAccess Control PointBerrien County Gov't Complex,2100 E. Empire Ave., Benton Harbor, MI. 49022Law Enforcement Representative in the EOC.In sync with scenarioCarol Wolfinger517-648-8598MS-1See Van BurenN/AN/AN/A 78 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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VAN BUREN COUNTYFACILITYADDRESSCONTACT PERSONACTIVATION TIMECONTROLLER EOCVan Buren County Sheriff Office205 S Kalamazoo St Paw Paw, MI 49079Al Svilpe 269-657-7786In sync with scenario.Audrey Walter517-230-4308 DosimetryVan Buren County Health Department 57418 CR 681 Hartford, MI 49057 Al Svilpe269-657-7786In sync with scenarioAudrey Walter517-230-4308Emergency Worker and Vehicle Decontamination N/A N/AN/AN/APublic Reception/ DecontaminationN/AN/AN/AN/APublic Reception/ Vehicle DecontaminationN/AN/AN/AN/APublic Congregate CareMattawan HS24959 McGillan AveMattawan MIAl Svilpe269-657-7786Tuesday, October 30, 2012 4pmTonya Nobach517-242-6505Access Control PointEOCLaw Enforcement Representative in the EOCIn sync with scenarioAudrey Walter517-230-4308EV-2 School InterviewCovert Public School35323 M-140Covert, MI 49043 Al Svilpe269-657-7786Monday, October 29, 20129:00 amTonya Nobach517-242-6505EAS InterviewWSJM580 East Napier AvenueBenton Harbor MI 49022 Al Svilpe269-657-7786In sync with scenario N/AMS-1South Haven Hospital955 S. Bailey AveSouth Haven MI 49090Jim Ridley269-569-0335Thursday, November 1, 2012, 9:00 amTonya Nobach517-242-6505MS-1Covert Fire Station74034 34 th AveCovert MI 49043Jim Ridley269-569-0335Thursday, November 1, 2012, 9:00 amTonya Nobach517-242-6505 79 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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STATE OF MICHIGAN EXTENT-OF-PLAY AGREEMENTOctober 30 and 31, 2012Extent of Play Agreements forAllegan, Berrien and Van Buren Counties and the State of Michigan2012 Palisades REP Exercise Objectives -Final Rev: October 19, 2012The exercise will take place on October 29 th, 30 thand 31 thof 2012. This exercise will involve out-of-sequence demonstrations (MS-1 on October 29, Emergency Worker Decontamination on October 30, EV-2 on October 11 thand radio stations on October 9 th and 11 th). The full scale Plume Phase exercise demonstration will be on October 30, 2012 and will include state and county EOC activations as well as the Joint Information Center (JIC).The State of Michigan, Allegan, Berrien and Van Buren Counties, South Haven Hospital (MS-1), Covert Fire/EMS Ambulance (MS-1), the Berrien Springs Fire Department (EWD) and the Covert Public School District, WSJM and Michigan Public Radio (MPR) are the off-site response organizations (OROs) for this exercise.Criteria that can be re-demonstrated immediately for credit, at the decision of the evaluator, include the following: 3.a.1, 3.b.1, 3.d.1, 3.d.2, 4.a.3, 4.b.1, 6.a.1, 6.b.1, 6.c.1 and 6.d.1. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chairperson of the Regional Assistance Committee, include the following: 2.a.1, 2.b.1, 2.b.2, 5.a.1 and 5.b.1. It is the desire of the State of Michigan to re-demonstrate (as needed) any areas of concern during the week of the exercise as possible.Evaluation Area 1 -Emergency Operations ManagementCriterion 1.a.1:Offsite Response Organizations (ORO)suse effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.State of Michigan1.The State Emergency Operations Center (SEOC) and Field Team Center (FTC) will be fully activated. State personnel reporting to the SEOC will be mobilized in accordance with procedures. 2.State personnel reporting to the county Emergency Operation Centers (EOC)s will be pre-positioned and will report when mobilized by the SEOC. 3.State personnel reporting to the FTC will be pre-positioned and will become operational at the time determined by the scenario and controller injects.4.State personnel reporting to the Joint Information Center (JIC) will be pre-positioned and will begin participation after the arrival of Allegan, Berrien and Van Buren County JIC personnel. 5.State personnel involved in out of sequence demonstrations will be pre-staged. 6.A roster willbe provided to demonstrate 24-hour staffing.Allegan County 1.The Allegan County EOC will be activated and mobilized in accordance with procedures. 2.Allegan County JIC personnel will be mobilized in accordance with procedures.3.All personnel involved in out of sequence demonstrations will be pre-positioned.

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4.A roster will be provided to demonstrate 24-hour staffing of the county EOC. Berrien County1. The Berrien County EOC will be activated and mobilized in accordance with procedures. 2. Berrien County JIC personnel will be mobilized in accordance with procedures.3. All personnel involved in out of sequence demonstrations will be pre-positioned.

4. A roster will be provided to demonstrate 24-hour staffing of the county EOC. Van Buren County 1. The Van Buren County EOC will be activated and mobilized in accordance with procedures. 2.Van Buren County JIC personnel will be mobilized in accordance with procedures.3.All personnel involved in out of sequence demonstrations will be pre-positioned. 4.A roster will be provided to demonstrate 24-hour staffing of the county EOC. Criterion 1.b.1:Facilities are sufficient to support the emergency response.State of Michigan1.The SEOC is maintained in operational readiness and set up will not be demonstrated.2.The FTC will be partially set up on Monday, October 29, 2012 and the balance of operations set up on Tuesday, October 30, 2012. The facility setup will be evaluated on Tuesday, October 30, 2012.3.The JIC is maintained in operational readiness and set up will not be demonstrated, however adequacy of the facility will be evaluated on Tuesday, October 30, 2012. Location: 330 W. Main St., Benton Harbor, Michigan. 4.The Department of Environmental Quality (DEQ) Laboratory is maintained in operational readiness and set up will not be demonstrated, however adequacy of the facility will be evaluated on Monday, October 29, 2012. Location: 815 Filley St., Lansing, Michigan.Allegan County1. The Allegan County EOC is maintained in operational readiness andset up will not be demonstrated.Berrien County 1. The Berrien County EOC is maintained in operational readiness and set up will not be demonstrated. Van Buren County 1. The Van Buren County EOC is maintained in operational readiness and set up will not be demonstrated.Criterion 1.c.1:Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. State of Michigan, Allegan County, Berrien County and Van Buren County1. This criterion will be demonstrated at the SEOC, county EOCs, FTC, and the JIC.Criterion 1.d.1:At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

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State of Michigan, Allegan County, Berrien County and Van Buren Counties 1. This criterion will be demonstrated by the SEOC, county EOCs, FTC, JIC, Public Reception/Emergency Worker Decontamination Centers, and Access Control. If both the primary and back-up systems fail, this objective may be demonstrated by successful use of an alternate method of communication.Criterion 1.e.1:Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.State of Michigan1.Equipment, maps, displays, and other supplies will be demonstrated to support emergency operations at the SEOC, JIC, FTC, counties EOCs and out of sequence events. 2.Personnel involved in traffic and access control points will demonstrate knowledge of whereto secure traffic control equipment3.Additional supplies of potassium iodide are stored at the Michigan State Police Emergency Management Homeland Security Division (MSP/EMHSD) office in Lansing. These supplies are meant to augment the counties' supplies.4.Additional direct reading dosimeters are stored at Michigan Department of Environment Quality (MDEQ) warehouse in Lansing. These supplies are meant to augment the county supplies, for county personnel.5. MDEQ maintains supplies of potassium iodide and dosimeters for use by Statepersonnel. 6. Documentation related to emergency worker KI shelf life extension is maintained by MSP/EMHSD and will be provided to FEMA at the Pre-Exercise Briefing along with instrument calibrationdata.Allegan County, Berrien County and Van Buren County1.Equipment, maps, displays, and other supplies will be demonstrated to support emergency operations at the SEOC, JIC, FTC, county EOCs and out of sequence events. 2.Personnel involved in traffic and access control points will demonstrate knowledge of where to secure traffic control equipment. 3. Potassium iodide and dosimeters are stored at the counties.Evaluation Area 2 -Protective Action Decision MakingCriterion 2.a.1:OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.State of Michigan1.The ability to make the decision to recommend the use of KI to emergency workers will be demonstrated by the SEOC. 2.Authorization to exceed State exposure limits will be demonstrated. If the scenario does not provide an opportunity to demonstrate these items, a controller inject will be issued to demonstrate the ability to perform these actions. Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.

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Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chairman of the Regional Assistance Committee.Criterion 2.b.1:Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.State of Michigan1.The Technical Support Group (TSG) in the SEOC will evaluate licensee and FTC provided information, and complete an independent analysis of scenario data. 2.Dose assessment will be conducted at the FTC and the results will be sent to the SEOC for further analysis during the plume phase.3.Completed dose assessment will be provided to the SEOC through controller injects for the post-plume phase.4. Post-plume dose assessment done at the FTC will not be sent to the SEOC. Data transmission will be simulated.Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chairman of the Regional Assistance Committee

.Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADs) for the general public (including the recommendation for the use of KI, if it is ORO policy).State of Michigan1.This criterion will be demonstrated by the Incident Management Group in the SEOC in conjunction with applicable support staff including the TSG and the Michigan Department of Community Health (MDCH).2.The Potassium Iodide (KI) policy will be demonstrated at the General Emergency declaration through a press release at the JIC and through SEOC discussion. Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chairman of the Regional Assistance Committee.Criterion 2.c.1:Protective action decisions are made, as appropriate, for groups of people with disabilities and those with access/functional needs.State of Michigan1. This criterion will be demonstrated by the Incident ManagementGroup in the SEOC inconjunction with applicable support staff, through the decision to recommend the use of KI to institutionalized persons that can not be evacuated.Allegan County 83 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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1.Lists of transportation dependent and functional needs populations are kept by the county. No personnel will be moved. No phone calls to transportation dependent persons will be made. Simulation of calls will be logged as such.2.Equipment lists and rosters will be available in the county EOC.3.The School Services Representatives in the Allegan County EOC will make phone contact with affected school districts. No scenario information will be discussed during these calls. Berrien County1.Lists of transportation dependent and functional needs populations are kept by the county. No personnel will be moved. No phone calls to transportation dependent persons will be made. Simulation of calls will be logged as such.2.Equipment lists and rosters will be available in the county EOC.3.The School Services Representatives in the Berrien County EOC will make phone contact with affected school districts. No scenario information will be discussed during these calls. Van Buren County 1. Lists of transportation dependent and functional needs populations are kept by the county. No personnel will be moved. No phone calls to transportation dependent persons will be made. Simulation of calls will be logged as such. 2. Equipment lists and rosters will be available in the county EOC.3.The School Services Representatives in the Van Buren County EOC will make phone contact with affected school districts. No scenario information will be discussed during these calls. Criterion 2.d.1:Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.State of Michigan 1.The State of Michigan, at the FTC, will demonstrate the capability to project dose to the public resulting from the ingestion exposure pathway. Dose projections will be based on simulated lab results provided by controller injects. Due to SEOC and FTC operating independently dose projection transmission will be simulated.2.The State will assess the radiological consequences of a release on the food and water supplies. The radiological impacts on the food and water will then be compared to the appropriate ingestion PAGs or Derived Intervention Levels (DIL). 3.SEOC will make appropriate Protective Action decisions based on ingestion exposure pathway dose projections information provided by the controller injects. 4.The State will demonstrate effective coordination with Federal and private exercise participants. Allegan County, Berrien County and Van Buren County This criterion does not apply.

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Criterion 2.e.1:Timely post-plume re-location, re-entry and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures.State of Michigan -State Emergency Operations Center (SEOC) 1. The State will demonstrate the capability to develop decisions on relocation, re-entry, and return at the SEOC. The assessment of the radiological conditions impacting the RRR will be made at the State FTC.

2. Relocation: The State will demonstrate the capability to estimate integrated dose in contaminated areas, compare these estimates with PAGs, and apply decision criteria for relocation of those individuals in the general public who have not been evacuated but where projected doses are in excess of relocation PAGs. Control access to evacuated areas and make appropriate decisions for relocating members of the public where residual radiation levels exceed PAGs (SEOC).3. Re-entry: The State will demonstrate policy based authorized access and exposure control for emergency workers and members of the general public requiring temporary entry to evacuated areas.

4. Return: The State Ingestion Pathway Committee will demonstrate effective decision making based on environmental data, political boundaries, and physical/geological features, to identify areas where the general public may return. 5. The State will demonstrate effective coordination with Federal and private exercise participants. Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Evaluation Area 3 -Protective Action ImplementationCriterion 3.a.1:The OROs issue appropriate dosimetry, KI and procedures, and manage radiological exposure to emergency workers in accordance with the plan and procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.State of Michigan1. This criterion will be demonstrated by the State of Michigan at the Field Team Center. Allegan County 1. This criterion will be demonstrated by Allegan County at the Allegan County EOC. Berrien County1. Berrien County will demonstrate this criterion out of sequence at the Public Reception/Emergency Worker Decontamination Centers. 2. Berrien County will demonstrate this criterion at the access control point when emergency workers are issued dosimeters.Van Buren County1. This criterion will be demonstrated by Van Buren County at the Van Buren County EOC.

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Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chairman of the Regional Assistance Committee.Criterion 3.b.1:KI and appropriate instructions are available in case a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals and general public is maintained.State of Michigan1. The State will demonstrate this objective at the SEOC and through decision-making and directives to implement appropriate Protective Action Orders.Allegan County1. Allegan County will demonstrate the ability (simulate) to administer KI to institutionalized individuals.Berrien County1. Berrien County will demonstrate the ability (simulate) to administer KI to institutionalized individuals.Van Buren County1. Van Buren County will demonstrate the ability (simulate) to administer KI to institutionalized individuals.Criterion 3.c.1:Protective Action Decisions (PADs) are implemented for people with disabilities and those with access/functional needs other than schools within areas subject to protective actions. State of MichiganThis criterion willnot be demonstrated by the State. Allegan County 1.This criterion will be demonstrated in the EOC via staff discussions that may include evacuation of hospitals, nursing homes, correctional facilities, mobility impaired individuals, and transportation dependent. These discussions will be documented in situation logs. 2.Actual contacts to special population groups will not be made. Simulation of calls will be logged as such. 3.Allegan County will contact a minimum of four providers of transportation services, which may include public transit authorities, school systems for buses, ambulance services, or fire/rescue services. An endeavor will be made to contact a third of the total number of transportation providers. There will be no discussion of scenario information during these calls.Berrien County 1. This criterion will be demonstrated in the EOC via staff discussions that may include evacuation of hospitals, nursing homes, correctional facilities, mobility impaired individuals, and transportation dependent. These discussions will be documented in situation logs. 2. Actual contacts to special population groups will not be made. Simulation of calls will be logged as such. 3. Berrien County will contact a minimum of four providers of transportation services, which may include public transit authorities, school systems for buses, ambulance services, or fire/rescue services. An endeavor will be made to contact a third of the total number of 86 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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transportation providers. There will be no discussion of scenario information during these calls.Van Buren County 1.This criterion will be demonstrated in the EOC via staff discussions that may include evacuation of hospitals, nursing homes, correctional facilities, mobility impaired individuals, and transportation dependent. These discussions will be documented in situation logs. 2.Actual contacts to special population groups will not be made. Simulation of calls will be logged as such. 3.Van Buren County will contact a minimum of four providers of transportation services, which may include public transit authorities, school systems for buses, ambulance services, or fire/rescue services. An endeavor will be made to contact a third of the total number of transportation providers. There will be no discussion of scenario information during these calls.Criterion 3.c.2:OROs/School officials implement protective actions for schools.State of MichiganThis criterion does not apply.Allegan County This criterion does not apply Berrien County This criterion does not apply.Van Buren County 1.This criterion will be demonstrated by Van Buren County EOC as driven by the scenario. 2. EV-2 interview will be conducted in Van Buren County at Covert Public Schools. Refer to the Table of Exercise Demonstrations for specific times. This will be conducted out of sequence. Criterion 3.d.1:Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.State of Michigan1.This criterion will be demonstrated by the SEOC through the restriction of air, rail, and waterway access.2.The state will demonstrate one access control point. Demonstration locations will be determined during the exercise at a time agreed upon by FEMA evaluator and the Exercise Controller at the FTC. 3.Staffing of all other access and traffic control points will be simulated. Allegan County1.Decisions related to traffic and access control will be demonstrated in the Allegan County EOC. Allegan County demonstration locations will be determined during the exercise at a time agreed upon by the FEMA evaluator, the Exercise Controller, and the county Emergency Management Coordinator.2.Staffing of all other access and traffic control points will be simulated.

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Berrien County1. Decisions related to traffic and access control will be demonstrated in the Berrien County EOC. Berrien County demonstration locations will be determined during the exercise at a time agreed upon by the FEMA evaluator, the Exercise Controller, and the county Emergency Management Coordinator.2.Staffing of all other access and traffic control points will be simulated.Van Buren County1.Decisions related to traffic and access control will be demonstrated in the Van Buren County EOC. Van Buren County demonstration locations will be determined during the exercise at a time agreed upon by the FEMA evaluator, the Exercise Controller, and the county Emergency Management Coordinator.2.Staffing of all other access and traffic control points will be simulated.Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator. Criterion 3.d.2:Impediments to evacuation are identified and resolved.State of MichiganThis criterion does not apply.Allegan County1. This will be demonstrated through discussions at the county EOC. Messages will be injected by Exercise Controllers to drive these demonstrations. Personnel will deal with the impediments by discussing the need for equipment, discussing its estimated time of arrival, etc. If the impediment posed involves road closures that would have been known to exercise participants during the course of normal operations, this information will be provided to the players as part of the initial conditions for the exercise. All contacts, actual or simulated will be logged.Berrien County1. This will be demonstrated through discussions at the county EOC. Messages will be injected by Exercise Controllers to drive these demonstrations. Personnel will deal with the impediments by discussing the need for equipment, discussing its estimated time of arrival, etc. If the impediment posed involves road closures that would have been known to exercise participants during the course of normal operations, this information will be provided to the players as part of the initial conditions for the exercise. All contacts, actual or simulated will be logged.Van Buren County 88 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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1. This will be demonstrated through discussions at the county EOC. Messages will be injected by Exercise Controllers to drive these demonstrations. Personnel will deal with the impediments by discussing the need for equipment, discussing its estimated time of arrival, etc. If the impediment posed involves road closures that would have been known to exercise participants during the course of normal operations, this information will be provided to the players as part of the initial conditions for the exercise. All contacts, actual or simulated will be logged.Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.Criterion 3.e.1:The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions.State of Michigan 1. The State will demonstrate the capability to implement protective actions for the ingestion exposure pathway at the SEOC. 2. The State will demonstrate effective coordination with Federal and private exercise participants.Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Criterion 3.e.2:Appropriate measures, strategies and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.State of Michigan1. Development of measures and strategies for implementation of ingestion pathway zone (IPZ) protective actions will be demonstrated by the State via formulation of protective action information for the general public, food producers, and food processors.The State will demonstrate the capability to control, restrict or prevent distribution of contaminated food by commercial sectors. Exercise play will include demonstration of communications and coordination between organizations to implement protective actions. Actual field play of implementation activities will be simulated. For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ will be demonstrated, but actual communications with food producers and processors may be simulated. Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Criterion 3.f.1:Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented.State of Michigan -SEOC 1.The State will demonstrate the capability to implement appropriate measures for relocation, re-entry and return.

2.Relocation: The State will demonstrate the capability to coordinate and implement decisions concerning relocation of individuals not previously evacuated to an area where radiological contamination will not expose the general public to doses that exceed the relocationPAGs. The State will also demonstrate the capability to provide for short-term or 89 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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long-term relocation of evacuees who lived in areas where residual radiation levels exceed PAGs. 3.Re-entry: The State will demonstrate the decision making process to determine which individuals/groups will be allowed re-entry. This will be demonstrated through discussions during the Day 2 Table-Top Exercise.

4.Return: The Ingestion Pathway Committee (IPC) will demonstrate the capability to implement policies concerning return of members of the general public to areas evacuated during the plume phase. The IPC will demonstrate the capability to prioritize services and facilities requiring short term restoration, and then identify procedures and resources for their restoration. Examples include medical services, social services, utilities, roads and schools.5. The State will demonstrate effective coordination with Federal and private exercise participants.State of Michigan -FTC1.The FTC will demonstrate the capability to implement appropriate measure for Re-entry and return.

2.Re-entry: The FTC will demonstrate the capability to control access and egress of individuals to evacuated areas. Radiation exposure will be assessed. 3.The State will demonstrate effective coordination with Federal and private exercise participants.Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Evaluation Area 4 -Field Measurement and AnalysisCriterion 4.a.1: (RESERVED)Criterion 4.a.2:Field teams (two or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure.State of Michigan1.This criterion will be demonstrated during the plume phase of this exercise at the Field Team Center (FTC) by the State.2.Field measurements will be taken to help characterize the release and to support the adequacy of implemented protective actions or to be a factor in modifying protective actions. Teams will be directed to take measurements in such locations, at such times to provide information sufficient to characterize the plume impacts.Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Criterion 4.a.3:Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the planand/or procedures) amount of radioactivity has been collected on the sampling media. 90 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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State of MichiganThis criterion will be demonstrated during the plume phase of this exercise at the Field Team Center (FTC) by State personnel. Two field teams will demonstrate the capability to reportmeasurements and field data pertaining to the measurement of airborne radioiodine andparticulates to the Field Team Center Coordinator (FTCC).Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Criterion 4.b.1:The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.State of Michigan 1.This criterion will be demonstrated at the FTC on October 31, 2012 out-of-sequence with the SEOC table-top. Controller injects at the Field Team Center will simulate decisions made at the SEOC by the IPC. 2.Three State field teams will demonstrate the ability to map the 20 uR/hr (contamination) and 1000 uR/hr (relocation) footprints. Two teams will demonstrate the ability to locate and communicate several points along the 20 uR/hr isopleth. One team will demonstrate the abilityto locate and communicate several points along the 1000 uR/hr isopleth. The number of points established will be sufficient to demonstrate the process used but a complete mapping of the areas will not be demonstrated. The complete mapping of these regionswill be provided by a Field Team Center controller.3.The State will demonstrate the use of equipment and procedures for the collection and transportation of samples from areas that received deposition from the airborne plume. 4.The State field teams will demonstrate the capability to take measurements and samples, at such times and locations as directed, to enable an adequate assessment of the ingestion pathway and to support re-entry, relocation, and return decisions Three field teams (two teams being from MDEQ and one team being from MDARD) will demonstrate the ability to collect, label, and properly use chain-of-custody forms for environmental samples as assigned by FTC Coordinator. These samples will include soil, grass, water, and vegetation. Each team will be assigned 1-2 sample types and locations for proper demonstration.5.The State will demonstrate effective coordination with Federal and private exercise participants.Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Criterion 4.c.1:The laboratory is capable of performing required radiological analyses to support protective action decisions.State of Michigan1. The State will demonstrate laboratory operations and procedures for measuring and analyzing samples.2. This criterion will be demonstrated at the DEQ Radiological Protection Laboratory (RPL) in Lansing on Monday, October 29, 2012 out-of-sequence with all other response activities.3. The DEQ RPL is appropriately equipped to provide analyses of media, as requested, on a timely basis, of sufficient quality and sensitivity to support assessments and decisions as 91 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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anticipated by the State's plans and procedures. New or revised methods may be used to analyze atypical radionuclide releases if warranted by circumstances of the event. Analysis may require resources beyond those of the State.4. The laboratory staff is qualified in a radioanalytical techniques and contamination control procedures5. The State will demonstrate effective coordination with Federal and private exercise participants.Allegan County, Berrien County and Van Buren CountyThis criterion does not apply.Evaluation Area 5 -Emergency Notification and Public InformationCriterion 5.a.1:Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP guidance. State of MichiganThe State will provide information to the county for release in the Emergency Alert System messages.Van Buren CountyThe Van Buren County Sheriff's Department is the primary activation point for the public warning sirens. Van Buren County also activates the Emergency Alert System. An interview with WSJM personnel will be conducted by FEMA following transmittal of EAS messages.Allegan County & Berrien CountyAllegan and Berrien Counties will provide, as needed, information to Van Buren County for inclusion in EAS messages. Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chairman of the Regional Assistance Committee.Criterion 5.a.2:[RESERVED]Criterion 5.a.3:Backup alert and notification of the public is completed within a reasonable time following detection by the ORO of a failure of the primary alert and notification system.Note: This criterion does not apply to this exercise.Criterion 5.a.4:Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notifythe public of an emergency situationThe Palisades EPZ does not contain any DHS/FEMA approved exception areas. This criterion will not be demonstrated during this exercise.

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Criterion 5.b.1:OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.State of Michigan, Allegan County, Berrien County & Van Buren County 1. This will be demonstrated at the JIC via dissemination of emergency information and instructions through joint media briefings and news release announcements in coordination with the SEOC and County EOCs. All media briefings will be conducted at the JIC.2. A public inquiry hotline will be operated by Entergy personnel based at the JIC during the exercise. Trending is performed by the Public Inquiry Coordinator, who identifies trends and ensures appropriate information is provided to the public inquiry operators and the JIC for inclusion in media briefings.Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chairman of the Regional Assistance Committee.Evaluation Area 6 -Support Operation/FacilitiesCriterion 6.a.1:The reception center has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees.State of Michigan1.State level emergency worker decontamination will be demonstrated at the FTC on October 30, 2012. 2.State personnel will provide assistance as requested during county Public Reception/Emergency Worker decontamination center demonstrations.Allegan County 1.Allegan County will fully demonstrate public reception/decontamination center out-of sequence from the exercise at Fennville High School. (Otsego High School was demonstrated in 2010.)2.Public reception centers will demonstrate 1/3 of the monitoring teams required to monitor 20% of the population allocated to that facility within a 12-hour period. One team will monitor six individuals. Berrien County 1.Berrien County will fully demonstrate separate public reception/decontamination center out-of sequence from the exercise at Berrien Springs High School. 2.Public reception centers will demonstrate 1/3 of the monitoring teams required to monitor 20% of the population allocated to that facility within a 12-hour period. One team will monitor six individuals. Van Buren County This criterion was demonstrated at Gobles and Paw Paw High Schools in 2008 and 2010. There for will not be demonstrated in 2012.Note: The decontamination and washing of vehicles and individuals, if detailed in the county plans, will be simulated.Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.

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Criterion 6.b.1:The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles.State of MichiganState of Michigan personnel will only demonstrate this criterion at the State Field Team Center (FTC). State emergency equipment and vehicles will be monitored and decontamination will be simulated, as appropriate. This criterion will be demonstrated on October 30, 2012. State personnel will provide assistance as requested during county Public Reception/Emergency Worker decontamination center demonstrations. Allegan CountyThis criterion was demonstrated in 2010 at Graafschap Fire Dept. and will not be demonstrated during this exercise. Berrien CountyBerrien County will fully demonstrate the emergency worker/equipment decontaminationcenter out of sequence with the exercise at Watervliet High School. Van Buren CountyThis criterion was demonstrated in 2010 at the Decatur/Hamilton Fire Dept. and will not be demonstrated during this exercise Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.Criterion 6.c.1:Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. Managers demonstrate the procedures to assure that evacuees have been monitored forcontamination and have been decontaminated as appropriate prior to entering congregate care facilities.State of MichiganThis criterion does not apply.Allegan County1. Allegan County will fully demonstrate a congregate care center out of sequence with theExercise at Fennville High School. Personnel operating the center will not go through alert, mobilization, activation, or shift changes. Appropriate 24/7 staffing will be demonstrated via personnel rosters, call-up lists, etc. Berrien County1. Berrien County will fully demonstrate a congregate care center out of sequence with theExercise at Berrien Springs High School. Personnel operating the center will not go through alert, mobilization, activation, or shift changes. Appropriate 24/7 staffing will be demonstrated via personnel rosters, call-up lists, etc.Van Buren County1. Van Buren County will fully demonstrate a congregate care center out of sequence with the exercise at Mattawan. Personnel operating the center will not go throughalert, 94 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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mobilization, activation, or shift changes. Appropriate 24/7 staffing will be demonstrated via personnel rosters, call-up lists, etc.Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator. Criterion 6.d.1:The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. Note: This criterion will be demonstrated during the MS-1 exercise. This criterion will be demonstrated on Thursday, November 1, 2012, at South Haven Hospital.Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.

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OFFSITE MEDICAL DRILLEXTENT of PLAYSouth Haven HospitalSouth Haven, MINovember 1, 2012Start Time 09:00 a.m.MI -Medical Drill November 1, 2012Rev: October 19, 2012Location: South Haven Health Systems Hospital955 S. Bailey Ave.

South Haven, MI 49090Transportation Provider: Covert Fire/EMS Lead Controller: Jim RidleyMSP/EMHSD Covert Fire/EMS Controller: Tonya Nobach Medical/Rad Controller: Provided by Palisades Victim: Provided by Palisades MDEQ ER Monitor: MDEQ Staff MDEQ Ambulance Monitor: MDEQ Staff Covert Fire/EMS: Staff South Haven Health Systems: StaffCriteria that can be re-demonstrated immediately for credit, at the discretion of theevaluator, include the following: For Transportation: 1.d.1, 3.a.1 and 6.d.1; for the Hospital, 1.d.1, 1.e.1, 3.a.1 and 6.d.1. Criteria may be re-demonstrated, as agreed by the Lead Controller, MSP/EMHSD Controller and FEMA Evaluator(s).Evaluation Area 1 -Emergency Operations ManagementCriterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.Covert Fire/EMS will use 2-way radios to communicate with South Haven Hospital. Other communication systems that can be used include commercial telephone or cell phones.Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

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South Haven Hospital will adequately demonstrate the ability to support operations, with adequate resources. The availability of dosimetry and KI for hospital personnelwill be demonstrated during this exercise, Covert Fire/EMS staff will also be issued dosimetry and KI (by the lead controller) as field team members.Evaluation Area 3 -Protective Action ImplementationCriterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposureto emergency workers in accordance with the plan and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.The use of dosimetry and KI will bedemonstrated by hospital staff and ambulance crew. For the purpose of this drill the ambulance exercise controller will simulate issuing dosimetry and KI to the ambulance crew in lieu of the emergency worker decontamination center.MDEQ staff will be arriving from the Field team center. To which they have already been briefed and given their dosimetry packets.For purposes of this exercise, if there is no medical need to bring equipment into and out of the treatment room, swabs will be taken at the injury locations and passed out of the room to demonstrate movement of equipment and supplies into and out of the controlled area.Evaluation Area 6.D -Transportation And Treatment Of Contaminated Injured IndividualsCriterion 6.d.1: The facility/ORO has theappropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.The hospital will demonstrate procedures for limiting exposure to hospital staff, decontaminating a patient, and restricting access to the area where the patient is being treated and monitored.Covert Fire/EMS will demonstrate the capability to transport a contaminated, injured individual to South Haven Hospital. The ambulance crew willpick up a contaminated injured patient near the Palisades Nuclear Plant (should inclement weather conditions exist, the Lead Controller may simulate the outdoor accident scene and begin the drill from an indoor location within the Palisades Owner Controlled Area). The ambulance crew will be met by Michigan Department of Environmental Quality (MDEQ) staff that will perform initial radiation monitoring, and will provide information regarding contamination levels on the patient

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to minimize the spread of contamination focusing on treating the patient's edical condition.Covert Fire/EMS will call in the information regarding the patient to South Haven Hospital so they canprepare for receipt of a contaminated patient. MDEQ personnel will accompany the patient to the hospital along with the ambulance, bringing instrumentation to provide radiation readings and guidance to the hospital.South Haven Hospital will implement their plan for receipt, isolation and treatment of an injured contaminated patient. Two hospital staff members will demonstrate proper donning and doffing of full personal protective equipment (PPE). Upon completion of this portion of demonstration PPE requirements may be relaxed with the concurrence of the lead controller and FEMA evaluator.

Medical personnel will utilize universal precautions and good housekeeping practices to minimize the spread of contamination, and will focus on treating the patient's medical condition. Simple decontamination efforts will be demonstrated after the patient has been medically stabilized. MDEQ personnel will discuss the need to take additional samples for further radiological analysis. Hospital personnel will demonstrate their knowledge of who to call beyond MDEQ for assistance in Radiological Accidents (e.g., REAC/TS).For purposes of this exercise, another MDEQ staff member will be dispatched to South Haven Hospital with radiation detection and measurement equipment in advance of the ambulance arriving. The purpose of having two separate individuals for this exercise is to facilitate monitoring the ambulance and ambulance personnel so they are not kept out of service for an extended period of time.The drill will conclude with hospital representatives and MDEQ personnel supervising the removal of protective clothing and surveying of the emergency room and hospital personnel. MDEQ will also advise on the proper procedure for release or disposal of contaminated material. Termination will be at the discretion of the Lead Controller, MSP/EMHSD Controller and FEMA Evaluator(s) based on successful demonstration of objectives.Following the conclusion of the drill, a short critique will be held.

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STATE OF INDIANA EXTENT-OF-PLAY AGREEMENTCriteria that can be re-demonstrated immediately for credit, at the discretion of the evaluator, include the following: 3.a.1, 3.d.1, 3.d.2, 6.a.1, 6.b.1, 6.c.1 and 6.d.1. Criteria that may be re-demonstrated, as approved on a case-by-case basisby the Chairperson of the Regional Assistance Committee, include the following: 2.a.1, 2.b.1, 2.b.2, 5.a.1 and 5.b.1.2012 Palisades IPX: Indiana Extent-of-Play 17 January 2012 Assessment Area 1 -Emergency Operations Management Sub-element 1.a -Mobilization Criterion 1.a.1: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654/ FEMA-REP-1, A.1.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4) The Indiana Department of Homeland Security (IDHS) will be fully activated, along with response and support partners identified in the Indiana Ingestion Pathway Plan. The IDHS Watch Officers will implement notification procedures as defined in the Ingestion Pathway Plan and current Standard Operating Procedures. Additional partner state agency liaisons will be contacted and will report to the State Emergency Operations Center (SEOC). No personnel will be pre-positioned in the SEOC, except those individuals who work in this area daily. Indiana's Forward Operating Center (FOC) will be located at Indiana State Police Post 24 in Bremen, IN, 1425 Miami Trail, Bremen, IN 46506. The FOC will be fully activated with state and local personnel. FOC and sampling teammembers will be sent to Bremen the night before, to expedite opening of the FOC on the day of exercise play. Sub-element 1.b -Facilities Criterion 1.b.1: Facilities are sufficient to support the emergen cy response. (NUREG-0654/FEMA-REP-1, H.3; G.3.a;J.10.h; J.

12; K.5.b) This criterion will be demonstrated at the SEOC in Indianapolis and FOC in Bremen. Sub-element 1.c -Direction and Control Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654/FEMAREP-1, A.1.d; A.2.a, b; A.3; C.4, 6) 99 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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The ability to direct and control emergency response activities will be demonstrated at the SEOC and FOC, by leadership of those facilities, in accordance with current plans and procedures. Sub-element 1.d -Communications Equipment Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations. (NUREG-0654/FEMA-REP-1, F.1, 2) The IDHS Watch Desk serves as the 24-hour, 7-day a week initial answering and notification point for all state emergencies. Communications resources available to the Watch Desk Officers are WebEOC, voice-over-internet-protocol telephones, one (800) telephone line, telephonic and web conferencing capabilities, several two-way radio systems (800MHz, VHF, HF, satellite, and HAM), facsimile, microwave connection, and satellite linkage. These same capabilities are found within the SEOC, with some SEOC positions having different capabilities than others. The primary communication between the FOC and SEOC will be via cellular telephone and WebEOC. The FOC will also have access to email, voice-over-internet-protocol telephones, satellite linkage, and two-way radio. Sampling teams will primarily communicate with the FOC via 800MHz radios, with back-up being cellular phones. Sub-element 1.e -Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. Demonstration on the use of maps, equipment, and displays to support emergency operations will take place at the SEOC, FOC, and State Radiochemistry Lab. The availability of dosimetry will be demonstrated at the FOC and State Radiochemistry Lab. An equipment check will be performed at the FOC as well. Assessment Area 2 -Protective Action Decision-Making Sub-element 2.a -Emergency Worker Exposure Control Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, isin place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654/FEMA-REP-1, C.6; J.10. e, f; K.4) Exposure control will be demonstrated at the FOC and by sampling teams. With the minimal level of contamination expected in Indiana following an incident, many 100 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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portions of this element may not be demonstrated. Exposure limits will be kept in accordance with current plans and procedures. Sub-element 2.d -Radiological Assessment and Decision Making for the Ingestion Exposure Pathway Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria. (NUREG-0654/FEMA-REP-1, A.3; C.1, 4; D.4; J.9,11) The ability to assess radiological consequences will be demonstrated during the post-emergency phase of the exercise. Field measurements from sampling teams through the FOC will be supplied to the SEOC, along with measurements from the State Radiochemistry Lab to facilitate protective action decision making. This will be conducted in accordance with current plans and procedures. Assessment Area 3 -Protective Action Implementation Sub-element 3.a -Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to emergency workers. (NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4) All sampling team and laboratory staff who will be gathering, processing, and analyzing radioactive samples, will have dosimetry. Some laboratory staff will have permanent dosimetry, but any person without permanent dosimetry will have either non-self reading or self-reading dosimeters. Sub-element 3.e-Implementation of Ingestion Pathway Decisions Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk, and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions. NUREG-0654/FEMA-REP-1, A.3; C.1, 4; J.11) Acquiring this information will be demonstrated in the SEOC, along with access being available at the FOC. All information will be obtained and usedin accordance with current plans and procedures. Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for 101 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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contaminated water, food products, milk, and agricultural production. (NUREG-0654/FEMA-REP-1 , G.1, J.9, 11)This criterion will be demonstrated in the SEOC during the post-emergency phase.Assessment Area 4 -Field Measurements And AnalysisSub-element 4.b -Post-Plume Phase Field Measurements and Sampling Criterion 4.b.1: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making. This will be demonstrated by the sampling teams. Samples appropriate to the area and season will be collected and transported in accordance with standard operating procedures. This will be conducted at the direction of the FOC. Three (3) field teams will be evaluated. Sub-element 4.c -Laboratory Operations Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654/FEMA-REP-1, C.1, 3; J.11) The Indiana State Department of Health Radiochemistry Lab will be at full operation. Samples appropriate to the area will be delivered on the morning of the exercise to the lab in an out of sequence play operation. Samples will then be prepared and analyzed in accordance with standard operating procedures. Assessment Area 5 -Emergency Notification And Public Notification Sub-element 5.b -Subsequent Emergency Information and Instructions for the Public and the Media Criterion 5.b.1: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c) The IDHS Public Information Officer (PIO) is responsible for the preparation and dissemination ofmedia advisories to the public upon approval by the Governor, or his/her designee. Pre-scripted advisories are the primary method of notification to the public of the possible or actual emergency and are included in the Indiana Ingestion Pathway Plan. They were developed for use by the PIO to expedite the process of obtaining final approval by the Governor's office. During the exercise, the PIO will monitor actions and decisions made by the appropriate officials at the EOC. Media briefings will be conducted at the SEOC/JIC. An advisory will be issued to the media from the SEOC/JIC.

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Assessment Area 6 -Support Operations/Facilities Sub-element 6.b -Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles Criterion 6.b.1: The facility/ORO has adequate procedures and res ources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles. (NUREG-0654/FEMA-REP-1, K.5.a, b) This will be demonstrated at the FOC. One portal monitor will be set up during the demonstration. The ability to monitor and decontaminate emergency workers will be demonstrated. This will be conducted when sampling teams return to the FOC from the field. 103 Unclassified Radiological Emergency Preparedness Program (REP)After Action Report/Improvement PlanPalisades Nuclear Power Plant

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